Comment Response Document RSRP.006/03 · 5.1. Attachment 1 - Structure of Q-AMC/GM to QCAR ADR cover Regulation in comparison to EASA AMC/GM for aerodromes (including Amendment 1)

Comment Response Document RSRP.006/03

TE.RMP.00034-004 © Civil Aviation Authority of the State of Qatar. All rights reserved. Page 1 of 66 Proprietary document. Copies are not controlled. Confirm revision status through the Authority-Internet/Intranet.

Regulation laying down requirements and administrative procedures

related to aerodromes

and issue of acceptable means of compliance, guidance material and

certification specifications for aerodrome design NPA RSRP.006/03 ISSUE 0.1 OF 05/03/2017

EXECUTIVE SUMMARY

The Qatar Civil Aviation Authority (QCAA), under the Regulatory Structure and Regulations Program (RSRP), is in the process of restructuring its regulatory framework and aligning its safety regulations with those of the European Union (EU). The Objectives of the Authority are specified in Emiri Decree 45 of 2014 and amongst others, are to attain best standards and competencies and ensure civil aviation safety for air transportation and for aviation in general. The Regulation laying down requirements and administrative procedures related to aerodromes, pursuant to Articles 4, 5, 7 and 8 of Law No. 15 of 2002 on Civil Aviation, and the associated certification specifications for aerodrome design, have been proposed by Notice of Proposed Amendment (NPA) RSRP.006/03 on 05 March 2017. Only 9 (nine) comments on the QCAR ADR Regulation have been received until 13 April 2017 (i.e. the deadline published in the NPA). The deadline was postponed to 27 April 2017 on request by Hamad Airport International (HAI), but no additional comments were received by that date. This Comment Response Document (CRD) however contains individual responses to 130 (one hundred thirty) additional (late) comments for a total of one hundred thirty nine (139) comments received by 4 stakeholders until 15 May 2017 on the QCAR ADR Regulation. No comments on the certification specifications QCS ADR-DSN have been receved until 14 May 2017. The 32 late comments on the specifications, received only on 15 May 2017, will be considered in preparation of the second edition of such QCS ADR-DSN, planned anyway with the view of incorporating issues 3 and 4 of corresponding EASA CS (which would encompass ICAO State Letter type I, No. 2017/44). In general the comments were constructive and contributed to improve the quality of the proposed rules and therefore the majority of proposals have been accepted and incorporated into the resulting text. Several comments focused on the interface between the aerodrome operator and the service providers in the frame of inter-organisational safety management. More in detail 82 comments have been accepted or partially accepted; 20 were noted and 37 not accepted. The Authority hence proceeds with adoption and promulgation of QCAR ADR, as resulting from said accepted, partially accepted and noted comments, to ensure compliance with ICAO standards applicable to international aerodromes. In addition, the scope of the Regulation includes also domestic aerodromes open to public use and other aerodromes in Qatar. This Regulation is complemented by Accptable Means of Compliance (AMC) and Guidance Material (GM), Q-AMC/GM ADR and by certification specifications QCS ADR-DSN. Q-AMC/GM ADR have not been subject to consultation, but they are explained in this CRD. Furthermore, AMC/GM may be adjusted during actual implementation, while a second edition may be issued in due time. The proposed Regulation laying down requirements and administrative procedures related to aerodromes will enter into force on 31st May 2017and become applicable in it s entirety one year later.

Applicability Process map

Affected regulations and decisions:

QCAR ADR isue 5 of May 2014, which is repealed

Concept Paper:

Terms of Reference:

Rulemaking group:

RIA type:

Technical consultation during NPA drafting:

Duration of NPA consultation:

Review group:

Focused consultation:

CRD and publication date of the QCAR:

No

03 March 2016

no

None

Yes

2 months

No

No

31 May 2017

Affected stakeholders:

Aerodrome Operators

Service prviders at aerodromes (Air Traffic Services, Aeronautical Information, Rescue and Fire Fighting, maintenance of visual aids, apron management, ground handling)

Driver/origin: RSR Program

Reference: RSRP001/10

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Table of contents

1. Procedural information ................................................................................................. 6 1.1. The rule development procedure ............................................................................. 6 1.2. The structure of this CRD ....................................................................................... 6 1.3. The next steps in the procedure .............................................................................. 7

2. Responses to received comments................................................................................... 8 2.1. Detailed individual responses .................................................................................. 8 2.2. Simplified individual responses to additional detailed comments ................................ 38 2.3. Statistics ............................................................................................................ 50 2.4. Overview of the impact of accepted or partially accepted comments .......................... 51

3. Explanatory Note on first edition of Q-AMC/GM ADR ....................................................... 52 3.1. Issues to be addressed ........................................................................................ 52 3.2. Objectives .......................................................................................................... 53 3.3. Structure of the proposed AMC/GM for international aerodromes ............................... 53 3.4. Overview of the AMC/GM to the QCAR ADR Regulation ............................................. 54 3.5. Highlights of the proposed Q-AMC/GM for aerodromes ............................................. 55

3.5.1. General ........................................................................................................ 55 3.5.2. AMC/GM to Annex I (Part-ADR.DEF) Definitions ................................................ 55 3.5.3. AMC/GM to Annex II (Part-ADR.AR) Certification and oversight of aerodromes...... 55

3.5.3.1 AMC/GM to Supart A (General) of Annex II (Part-ADR.AR) ........................... 55

3.5.3.2 AMC/GM to Supart B (Authority's Management) of Annex II (Part-ADR.AR) .... 55

3.5.3.3 AMC/GM to Supart C (Oversight, certification and enforcement) of Annex II (Part-ADR.AR) ........................................................................................................ 55

3.5.3.4 AMC/GM to Supart D (Oversight following declaration) of Annex II (Part-ADR.AR)

56

3.5.3.5 AMC/GM to Supart E (Oversight following registration) of Annex II (Part-

ADR.AR) 56

3.5.4. AMC/GM to Annex III (Part-ADR.OR) Organisations at aerodromes ...................... 56 3.5.4.1 AMC/GM to Subpart A (General requirements) of Annex III (Part-ADR.OR) ..... 56

3.5.4.2 AMC/GM to Subpart B (Certification of aerodromes) of Annex III (Part-ADR.OR) 56

3.5.4.3 AMC/GM to Subpart C (Certification of aerodrome operators) of Annex III (Part-ADR.OR) 57

3.5.4.4 AMC/GM to Subpart D (Management of aerodrome operator) of Annex III (Part-

ADR.OR) 57

3.5.4.5 AMC/GM to Subpart E (reserved) of Annex III (Part-ADR.OR) ....................... 59

3.5.4.6 AMC/GM to Subpart F (Declarations) of Annex III (Part-ADR.OR) .................. 59

3.5.4.7 AMC/GM to Subpart G (Registration) of Annex III (Part-ADR.OR) .................. 59

3.5.4.8 AMC/GM to Subpart H (Manuals) of Annex III (Part-ADR.OR) .......................... 59

3.5.5. AMC/GM to Annex IV (Part-ADR.OPS) Aerodrome operations .............................. 60 3.5.5.1 AMC/GM to Subpart A (Aerodrome data) of Annex IV (Part-ADR.OPS) ........... 60

3.5.5.2 AMC/GM to Subpart B (Aerodrome services, equipment and installations) of Annex IV (Part-ADR.OPS) ......................................................................................... 60

3.5.5.3 AMC/GM to Subpart C (Aerodrome maintenance) of Annex IV (Part-ADR.OPS) 60

3.5.5.4 AMC/GM to Subpart D (Responsibility of the aerodrome operator on the apron) of Annex IV (Part-ADR.OPS) ..................................................................................... 60

3.5.5.5 AMC/GM to Subpart E (Apron management) of Annex IV (Part-ADR.OPS) ...... 61

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3.5.5.6 AMC/GM to Subpart F (Responsibility of the aerodrome operator for ground handling) of Annex IV (Part-ADR.OPS) ....................................................................... 61

3.5.5.7 AMC/GM to Subpart G (Ground handling) of Annex IV (Part-ADR.OPS) .......... 61

3.5.6. AMC/GM to Annex V (Part-ADR.SRP) Safeguarding of aerodromes surroundings ... 61

4. References ................................................................................................................ 62 4.1. Affected regulations ............................................................................................. 62 4.2. Affected CS ........................................................................................................ 62 4.3. Reference documents .......................................................................................... 62

5. Attachments .............................................................................................................. 63 5.1. Attachment 1 - Structure of Q-AMC/GM to QCAR ADR cover Regulation in comparison

to EASA AMC/GM for aerodromes (including Amendment 1) ............................................... 63 5.2. Attachment 2 - Structure of Q-AMC/GM to Annexes of QCAR ADR in comparison to EASA

AMC/GM for aerodromes (including Amendment 1) ........................................................... 64

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1. Procedural information

1.1. The rule development procedure

The Qatar Civil Aviation Authority (hereinafter referred to as the ‘Authority’) published Notice of Proposed

Amendment NPA RSRP.006/03 on 05 March 2017 pursuant to Articles 4, 5, 7 and 8 of Law No. 15 of

2002 on Civil Aviation and in compliance with the QCAR 11 Rulemaking Procedure.

This rulemaking activity is included in the Authority’s Regulatory Structure and Regulations Programme

2016 – 2018.

As a result of the public consultation on the NPA, 139 comments from four stakeholders have been

received until 15 May 2017, well beyond the original deadline of the previous 13 April in the NPA, which,

following request by Hamad Aiport International (HAI), had been postponed to 27 April.

Out of these 139 comments on the proposed QCAR ADR Regulation, 82 have been accepted or partially

accepted (59 %), 20 have been noted (14 %) and 37 have not been accepted (27 %) as presented in

detail in this Comment Response Document (CRD).

Until 14 May 2017 no comments have been received on the certification specifications QCS ADR-DSN,

proposed by mentioned NPA and modelled on:

issue 2 of corresponding EASA specifications (in turn based on Volume I of Annex 14 to the

Chicago Convention) for aerodromes having at least one runway for take-off and landing of fixed

wing aeroplanes; and

Volume II of Annex 14 to the Chicago Convention for heliports and helidecks, which has so far

no equivalent in EASA.

Only on 15 May 2017 (i.e. almost three weeks after the expiry of the already postponed deadline), 32

commets have been received on QCS ADR-DSN. These 32 comments are put on hold since:

Regulation QCAR ADR allows flexibility in applying the certification specifications, thorugh

controlled prcesses, should this be necessary;

A second edition of QCS ADR-DSN is anyway necessary to transpose:

o EASA issue 3 of the CS, issued on 08 December 2016;

o EASA issue 4 envisaged around end of 2017, based on EASA NPA 2017-04 of 11 April

2017; and

o Amendment of Volume I of Annex 14 to the Chicago Convention, proposed by ICAO State

Letter (type I) AN 4/1.1.57-17/44 of 19 April 2017, whose adoption is expected in 2018,

for applicability not earlier than the end of that year (transposition of this amendment in

the EU is already contained in mentioned EASA NPA 2017-04).

The 32 comments received on QCS ADR-DSN will hence be considred when preparing the second edition

of these certification specifications.

1.2. The structure of this CRD

Chapter 1 of this CRD contains the procedural information related to this task. Chapter 2 (responses to

comments) explains why the comments have been accepted or not and specifies the resulting impact on

the proposed rules. Chapter 3 contains an Explanatory Note on the related Q-AMC/GM ADR, which are

adopted and published without consultation.

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1.3. The next steps in the procedure

Following the closing of the NPA public consultation period of more than 70 days (i.e. almost 40 days

granted in the NPA, plus 15 of postponement following request by HAI, plus 18 additional days since late

comments have been accepted until 15 May 2017) and having responded to all received comments, the

Authority proceeds towards adoption and promulgation of the resulting text of:

a) the new QCAR ADR Regulation repealing former issue 5 of May 2014;

b) the associated first edition of the Acceptable Means of Compliance (AMC) and Guidance Material

(GM) essentially focused on international aerodromes); and

c) the related first issue of the certification specifications QCS ADR-DSN covering aerodromes with

at least one runway for take-off and landing of fixed wing aeroplanes, as well as heliports and

helidecks.

It should be noted that in previous QCAR ADR of 2014 also technical requirements had the status of

legally binding rules, making more difficult to adapt them to the evolution of the state of the art. On the

contrary only a) above is legally binding and containing identification of legal actors, establishment of

regulatory processes, as well as privileges and responsibilities of holders of certificates and of other

stakeholders.

The legally binding rules contain also provisions to adjust the Q-AMC/GM or QCS ADR-DSN to specific

needs or to the technical evolution.

The outcome of the NPA public consultation on the new QCAR ADR Regulation and on the QCS ADR-

DSN, as well as an explanatpry note on the Q-AMC/GM ADR which were not subject to public consultation,

are presented in this Comment-Response Document (CRD) which is published simultaneously with the

regulatory material listed above.

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2. Responses to received comments

2.1. Detailed individual responses

Comment No. 35 Originator of

comment AND Reviewers

Affected NPA paragraph

General

NPA text N.A.

Comment

The Qatar Law 15 of 2002, the Decree 45 of 2014 and the Authority Chairman Decree 6 of 2015 allocate clearly the delivery of the following services to Authority and more specifically its Air Navigation Department (AND): - Air Traffic Services (ATS), under the responsibility of Authority/AND, are provided within the Doha Terminal Area (TMA) airspace and in the vicinity of aerodromes of Qatar; - On the ground, ATS are provided to aircraft in the Movement Area (Runways, Taxiways, Aprons); - Authority/AND is responsible for the implementation, operation and maintenance of Communication, Navigation, Surveillance and Air Traffic Management (CNS-ATM) equipment for airspace and aerodromes in Qatar; - Aeronautical Information Management (AIM) services, under the responsibility of Authority/AND, are responsible in Qatar for all aspects related to data management, charting, procedures design, etc... - Last but not least, Aerodrome Rescue and Fire Fighting Services (ARFFS) are under the responsibility of Authority/AND at HIA & DIA. As it will be seen in the comments below a large majority is related to the sharing of responsibilities between the Authority/AND and the Aerodrome Operator should the latter is identified as the HIA operator, member of the Qatar Airways Group. Many requirements are ambiguous and depart from ICAO standards, which should be applied even if Qatar implement the EASA Regulations (which AND understood are compliant or over compliant to ICAO). The lack or limited amount of consultation of AND Specialists before publishing the NPA might be an explanation of the number of comments recorded.

Alternative text proposed by commentator

None

Response Accepted

Details of response

1. The role of Authority/AND to provide operational services at international aerodromes and at domestic aerodromes open to public use is acknowledged;

2. Comments by Authority/AND to remove ambiguities and better align QCAR ADR with ICAO requirements are appreciate and responded individualy below;

3. In ICAO the Procedures for Air Navigation Services (PANS) have a status higher than the recommendations in the Annexes to the Chicago Convention;

4. In fact no notification is required if the recommedations in the Annexes are not implemented;

5. On the contrary, although the PANS do not carry the status afforded to SARPs adopted by the ICAO Council as Annexes to the Convention and, therefore do not fall under the obligation imposed by Article 38 of the Convention to notify differences in the event of non-implementation, ICAO calls attention of States to the provision in Annex 15 related to the publication, in the Aeronautical Information Publication (AIP), of lists of significant differences between their procedures and the related ICAO procedures.

6. Non implementing key provisions of PANS, without publishing this fact in AIP, may hence lead to a finding during ICAO audits;

7. In 2015 ICAO published the first edition of PANS-ADR (Doc 9981) devoted to aerodromes;

8. Therein paragraph 2.4.2.1 establishes that the State verifies that coordination exists between the aerodrome operator, aeroplane operators, air navigation service providers and all other relevant stakeholders to ensure the safety of operations, which is implemented through the QCAR ADR Regulation.

9. Mentioned paragraph 2.4.2.1 of PANS-ADR hence mentions ‘aerodrome operators’, even if they are not explicitly defined in Annex 14;

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10. However that Annex defines ‘Certified Aerodrome’ as an aerodrome whose operator has been granted an aerodrome certificate, in other words recognising the existence of aerodrome operators;

11. In addition, paragraph 3.3.2.1 f) of the second edition of Annex 19, mandates safety management to be implemented by operators of aerodromes certified in accordance with Annex 14 (i.e. international);

12. That standard in Annex 19 is amplified by paragraph 2.4.2.2 of the PANS-ADR: “The aerodrome operator should ensure that all users of the aerodrome, including ground-handling agencies and other organizations that perform activities independently at the aerodrome in relation to flight or aircraft handling, comply with the safety requirements of the aerodrome operator. The aerodrome operator monitors such compliance.”

13. In summary:

The existence and role of the aerodrome operator is clearly defined in ICAO;

Since Qatar is an ICAO Contracting State the QCAR ADR are fully aligned with the above;

14. To make the above even clearer, while responding to this comment, recital (3) is slightly amended, while a new recital (4) and a new Article 4 are inserted in the cover Regulation QCAR ADR.

Resulting text

Whereas: … (3) International aerodromes should be designed, constructed, maintained and operated in compliance with the applicable international Standards and Recommended Practices contained in the Annexes to the Chicago Convention published by the International Civil Aviation Organization (hereinafter referred to as ‘ICAO’) and in particular with Annex 14 (aerodromes), Volumes I and II, Annex 9 (Facilitation) and Annex 19 (Safety management by aerodrome operators) and subject to certification. (4) in compliance with paragraph 2.4.2.1 of ICAO PANS-ADR (Doc 9981) this Regulation establishes how the State of Qatar verifies that coordination exists between the aerodrome operator, aircraft operators, air navigation service providers and all other relevant stakeholders and service providers to ensure the safety of operations at aerodromes. … Article 4 Aerodome Operator 1. The aerodrome operator shall ensure that all users of the aerodrome, including Air Traffic

Services, Aeronautical Ground Lighting, Rescue and Firefighting Services, Ground Handling service providers and other organizations that perform activities at the aerodrome in relation to flight or aircraft handling, comply with the Safety Management Systems of the aerodrome operator.

2. The aerodrome operator shall ensure that a formal mechanism is in place to regularly oversee, audit and inspect such services to satisfy themselves that regulatory and service levels of compliance are being maintained.




General

NPA text N.A.

Comment

The overall quality of the document is quite poor for a Notice of this kind and stakeholders' reviewers should not be considered as proof readers for a text of this importance and for the sake of Authority credibility. - Fast access to text is cumbersome as Table of Contents are not matching with sections/paragraphs/text; - Too many formatting issues; - Too many typos.

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One cannot find from the page numbering system where in the document he/she is navigating, e.g. Section, Annex, Subpart, ... very cumbersome.


None

Response Noted

Details of response

Apologies if the text of the NPA was not perfect. Thanks for the cmments provided by AND which will improve the quality of the final resulting text.

Resulting text No change to the proposed text is deemed necessary on the basis of this comment.




2.5.5 of the Explanatory Note

NPA text

Comment

Some assumptions are incorrect such as in para 2.5.5 item (1) to (5) on apron management services (see 35 above) Para 2.5.5 item (6) makes reference to a document [9] in italian (not acceptable) that may explain the requirements proposed for ground handling and apron management.


None

Response Noted

Details of response

1. Assumptions (4) and (5) in paragraph 2.5.5 of th explanatory note are factual and in ay case they have absolutely no impact on the choice of the entity which should provide apron management services.

2. There is not much evidence in the world of regulatory material concerning ground handling; this I why reference was made to anItalian regulation;

3. In any case neither the Explanatory Nte of the NPA, nor the list of references will be part of the promulgated QCAR ADR Regulation.



comment

Peter Budd Authority

ICAO Compliance Officer


4.3 of the Explanatory Note

NPA text

List of reference documents in paragraph 4.3 of the Explanatory Note; and

Recital (3) QCAR ADR: International airports should be designed, constructed, maintained and operated in compliance with the applicable international Standards and Recommended Practices contained in the Annexes to the Chicago Convention published by the International Civil Aviation Organization (hereinafter referred to as ‘ICAO’) and in particular with Annex 14 (aerodromes), Volumes I and II, Annex 9 (Facilitation) and Annex 19 (Safety management) and subject to certification.

Comment ICAO references: Adopting an Annex by reference binds the State to all of the content of the Annex, including recommendations


None

Response Noted

Details of response

The statement by the commentator is factual and correct. However in the NPA, ICAO Annexes are mentioned only in:

List of references in the Explanatory Note, which will not become part of the adopted regulation; and

In recital (3) which, like any recital, is only an explanatory preamble and not a rule. Thank you for having reminded us of this risk, which was anyway already mitigated.


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comment

Bernard Lucat Authority/AND [email protected]


Recital (5) (now 7)

NPA text Ground handling and apron management services should be provided at an aerodrome. In some cases ground handling is not directly provided by the aerodrome operator, ...

Comment apron management missing in 2nd sentence


to be applicable to Qatar (see comment 35 above, should read: In some cases ground handling and apron management are not directly provided by the aerodrome operator, ...

Response Accepted

Details of response

Apron management inserted in the recital, which is now numbered (7).

Resulting text In some cases ground handling and apron management are is not directly provided by the aerodrome operator, ...


comment C. Farnaby ASC Ltd


Art. 2 and Annex I

NPA text Lists of definitions

Comment No definition (of declaration) within Article 2 and Annex 1


Define Declaration

Response Accepted

Details of response

Three additional definitions included in Article 2:

Certification, modelled on Article 3(e) of EU Regulation 216/2008;

Declaration, modelled on ESA rule 21.A.608; and

Registration inspired by FAA Part 48.

Resulting text

Additional definitions: (8) ‘certification’ means any form of recognition issued by the Authority, that an aerodrome, product, equipment, organisation, service or person complies with the applicable requirements including the provisions of this Regulation, as well as the issuance of the relevant certificate attesting such compliance; (11) ‘declaration’ means any form of statement signed by an applicant, that an aerodrome, product, equipment, organisation, service or person complies with the applicable and identified requirements including the provisions of this Regulation; (21) ‘registration’ means a process enabling the Authority to identify an aerodrome or an aircraft and track its owner or operator.


comment



Art. 2(2)

NPA text 'aerodrome operator'

Comment This definition does not exist in Annex 14 and the limited wording proposed generates confusion. Definition should be completed with indication that the 'aerodrome operator' may not be responsible for all services, e.g. apron, ground handling (see 1.1 above), CNS, AGL, etc…


… heliports or helidecks. 'aerodrome operators' may not provide all services as required to operate under the delivered license.

Response Not accepted

Details of response

Although the term ‘aerodrome operator’ is not explicitly defined in ICAO, it is however used at least in Annex 14, Annex 19 and PANS-ADR;

The proposed definition is modelled on the definition of operator (of aircraft in that case) in ICAO Annex 6;

The definition is also in line with Article 3(h) of EU Regulation 216/2008.


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comment

Peter Budd Authority ICAO Compliance Officer


Art. 2(11)1

NPA text 'domestic aerodrome' means an aerodrome open to public use by non-scheduled civil flights, serving only traffic under Visual Flight Rules (VFR) and not routinely supporting formalities incident to customs, immigrations or public house quarantine.

Comment Al Khor: International GA aircraft use the airport without first landing at HIA. Such flights are not domestic.


None

Response Partially accepted

Details of response

The statement by the commentator is factual. And in fact non-scheduled international flights would continue to operate at Al Khor as is presently the case.

The NPA does not propose any change in the OPS regulations for international flights. It proposes provisions only for ‘domestic aerodromes’;

ICAO Annex 14 does neither define ‘international’ nor ‘domestic’ aerodromes;

ICAO Annex 9 defines ‘international airports’ as those aerodromes where facilitation is routinely provided;

The NPA hence proposes a new definition of ‘domestic aerodrome’;

Readers may note that nothing in the proposed text excludes non-scheduled international flights;

However, since satellite systems support Performance Based Navigation (PBN) anywhere, including for instrument flight procedures and since general aviation aircraft may be well equipped with satellite navigation, the text of the definition could be enhanced, removing the limitation to only VFR.

Resulting text 'domestic aerodrome' means an aerodrome open to public use by non-scheduled civil flights, serving only traffic under Visual Flight Rules (VFR) and not routinely supporting formality incidents to customs, immigrations or public house quarantine.

Comment No. 11 Originator of comment C Farnaby ASC Ltd Affected NPA

paragraph Art. 3(2)

NPA text

The Authority certification and oversight function shall b independent from any aerodrome operator and from any service provider, including of Air Traffic Services, ground handling or apron management, to ensure that the Authority exercise its powers impartially and transparently.

Comment Authority is utilised to describe the Authority


Authority

Response Accepted

Details of response

Term ‘Authority’ (instead than ‘Authority’) used throught the text.

Resulting text ‘Authority’ instead than ‘Authority’ throughout the cover Regulation and the five Annexes to it.


comment C Farnaby ASC Ltd


Art. 8 (now 9)

NPA text

1. The airspace around an aerodrome shall be safeguarded from obstacles so as to permit the intended aircraft operations at the aerodromes without creating an unacceptable risk caused by the development of obstacles around the aerodrome.

2. Safeguard maps shall be developed according to the certification specifications issued by the Authority, implemented and continuously monitored to identify any infringing penetration of the liitation surfaces contained in the maps.

1 Definition (13) in the resulting text

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3 Copies of safeguard maps shall be recorded and kept by the Authority and also be provided by the Authority to the Municipal Authorities responsible for urabn planning and related applications and permissions in the vicinity of the aerodrome concerned.

4. Any infringement of the surfaces in the safeguard maps requires an assessment to identify whether or not the object creates an unacceptable risk.

5. Any object posing an unacceptable risk shall be removed or appropriate mitigating action shall be taken to protect aircraft using the aerodrome.

6. Hazards related to human activities and land use, shall be authorised by the Authority before implementation or construction as detailed in Annex V.

Comment Clarity is required for the actions of the Authority


Clarify the responsibilities of the Authority to align with Annex V

Response Accepted

Details of response

Clarity of the text improved, as in resulting text below.

Resulting text

1. The airspace around an aerodrome shall be safeguarded from obstacles so as to permit the intended aircraft operations at the aerodromes without creating an unacceptable risk caused by the development of obstacles around the aerodrome.

2. The Authority, directly or supported by a service provider, shall develop and issue, safeguard maps shall be developed according to the certification specifications issued by the Authority. implemented and continuously monitored to identify any infringing penetration of the liitation surfaces contained in the maps.

3 Copies of safeguard maps shall be recorded and kept by the Authority or service provider Authority and also be provided by the Authority to the invoved aerodrome operator and to the Municipal Authorities responsible for urabn planning and related applications and permissions in the vicinity of the aerodrome concerned.

4. Any infringement of the surfaces in the safeguard maps requires a risk assessment to identify whether or not the object creates an unacceptable risk, as detailed in Annex V.

5. Any object posing an unacceptable risk shall be removed or appropriate mitigating action shall be taken to protect aircraft using the aerodrome.

6. Hazards related to human activities and land use, shall be authorised by the Authority before implementation or construction as detailed in Annex V.


comment

Pamela Erice Authority/AND [email protected]


Art. 8(2) (now 9(2))

NPA text liitation

Comment wrong spelling "liitation"


should read as "limitation"

Response Accepted

Details of response

Apologies for the typo.

Resulting text See response to comment 13 above.




Art. 8(3) (now 9(3))

NPA text Copies of safeguard maps shall be recorded and kept by the Authority and also be provided by the Authority to the Municipal Authorities responsible for urabn planning and related applications and permissions in the vicinity of the aerodrome concerned.

Comment Use of Authority in Paragraph 3

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Authority

Response Accepted

Details of response

Term ‘Authority’ (instead than ‘Authority’) used throught the text.

Resulting text ‘Authority’ instead than ‘Authority’ throughout the cover Regulation and the five Annexes to it.


comment

Pamela Erice Authority/AND [email protected]


Art. 8(3) (now 9(3))

NPA text urabn

Comment wrong spelling "urabn"


should read as "urban"

Response Accepted

Details of response

Apologies for the typo

Resulting text urbabn


comment

Franz Sammueller Authority/AND [email protected]

Affected NPA

paragraph

Art. 9 (now 10)

NPA text 1. The aerodrome operator shall monitor human activities and land use around the aerodrome,….

Comment Where are the specifications for the area covered by 'around the aerodrome'?


None

Response Accepted

Details of response

Text now linked to safeguard maps in previous Article.

Resulting text 1. The aerodrome operator shall monitor human activities and land use around the aerodrome inside the areas defined in the safeguard maps in 9.2, ….




Art. 10 (now 11)

NPA text

1. the Authority shall ensure that wildlife strike hazards are assessed through:

(a) the establishment of a domestic procedure for recording and reporting wildlife strikes to aircraft;

(b) the collection of information from aircraft operators, aerodrome operators and other sources on the presence of wildlife constituting a potential hazard to aircraft operations; and

(c) an ongoing evaluation of the wildlife hazard by competent personnel.

2. the Authority shall ensure that wildlife strike reports are collected and forwarded to ICAO for inclusion in the ICAO Bird Strike Information System (IBIS) database.

Comment The Authority should coordinate this function to ensure that the data is shared within the safety data area of the Authority for analysis across the relevant sectors of the Authority.


Define which area will co-ordinate this function within the Authority and who is (Dept)responsible for the sharing of the data across the Authority.


Details of response

Content is shared. Indeed the safety data collection and analysis function of the Authority should be involved also for occurrence reporting on bird strikes.

CRD RSRP.006/03


However, detailed rules on occurrence reporting are the subject of a different Regulation and not of this one.

Resulting text

1. the Authority shall ensure that wildlife strike hazards are assessed through:

(a) the establishment of a domestic procedure for safety occurrence reporting, including recording and reporting wildlife strikes to aircraft;

(b) The collection of information from aircraft operators, aerodrome operators and other sources on the presence of wildlife constituting a potential hazard to aircraft operations; and

(c) an ongoing evaluation of the wildlife hazard by competent personnel.

2. the Authority shall ensure that wildlife strike reports are collected and forwarded to ICAO for inclusion in the ICAO Bird Strike Information System (IBIS) database.


comment


Affected NPA

paragraph

Annex I par. (20) (now 19)

NPA text … in terms of accuracy, resolution and integrity.

Comment reference should be given where these terms can be found.


… in terms of accuracy, resolution and integrity as defined in QCAR-Part 15 (or ICAO Annex 15).


Details of response

References or requirements donot belong to definitions. The proposed definition is exactly as in current edition of ICAO Annex 15. Data quality requirements are in ADR.OPS.A.010 with details in related AMC/GM (NPA exected in May 2017), indeed on the basis of Annex 15 (15th edition, including amendment 39A).



comment


Affected NPA

paragraph

Annex I par. (22) (now (21))

NPA text Definitions for terms used in Annexes II to V; item (22)

Comment TORA, TODA, LDA definitions are repeted later (resp. 51, 50 & 31)


Suggest definitions are removed from 51, 50 & 31.

Response Accepted

Details of response

Indeed definition 22 in Annex I (‘declared distances’) already covers ASDA, LDA, TODA and TORA. No need include them in separate definitions.

Resulting text Definitions (2), (31), (50) and (51) removed. List renumbered accordingly.


comment


Affected NPA

paragraph


NPA text

Definitions for terms used in Annexes II to V; item (28): … i.IIIA: intended for operations with a decision height (DH) lower than 30 m (100 ft), or no decision height and a runway visual range (RVR) not less than 175 m; or

ii.IIIB: intended for operations with a decision height (DH) lower than 15 m (50 ft), or no decision height and a runway visual range (RVR) less than 175 m but not less than 50 m; or

…

Comment applicable minima should be the same as ICAO (175 m does not exist)

CRD RSRP.006/03



Correct accordingly


Details of response

Definition for ‘instrument runway’ is exactly (i.e. RVR minimum of 175 m does exist) as in Volume I of Annex 14 to the Chicago Convention (since amendment 11-A introduced into 6th edition, applicable as from 14 November 2013).



comment


Affected NPA

paragraph


NPA text

(40) other than Standard Category II operation’ means a precision instrument approach and landing operation using ILS or MLS where some or all of the elements of the precision approach Category II light system are not available, and with: …..

Comment What about other means, e.g. GBAS?


None

Response Accepted

Details of response

GBAS included.

Resulting text

(40) other than Standard Category II operation’ means a precision instrument approach and landing operation using GBAS, ILS or MLS where some or all of the elements of the precision approach Category II light system are not available, and with: …..


comment



ADR.AR.A.001

NPA text 1. This Annex establishes requirements for the Authority for regulation and oversight of

aerodromes located in the territory of the State of Qatar or on its territorial waters or in its exclusive economic zone, on ships registered in Qatar

Comment Regulation Applicability-Qatar economic zone: It is not assured that the legal basis is established for the applicability of Qatar regulation in the areas specified.


None


Details of response

Indeed there no legal basis in the Chicago Convention or its Annexes to regulate helidecks in the exclusive economic zone at sea. However, Article 56 of Part V of the UN Convention on the law of the sea, establishes that, in the exclusive economic zone, while navigation is free, the coastal State nevertheless has sovereign rights for the purpose of exploring and exploiting, conserving and managing the natural resources, whether living or non-living, of the waters superjacent to the seabed and of the seabed and its subsoil, and with regard to other activities for the economic exploitation and exploration of the zone, such as the production of energy from the water, currents and winds. As a consequence, inside the Qatar exclusive economic zone, the Authority has jurisdiction with regard to the establishment and use of artificial islands, installations and structures.

Resulting text

A new recital (4) is added on the basis of this comment: (4) Article 56 of Part V of the UN Convention on the law of the sea, establishes that, in the exclusive economic zone, the coastal State has sovereign rights for managing natural resources of the seabed and its subsoil. As a consequence, inside the Qatar exclusive economic zone, the Authority has jurisdiction with regard to the establishment and use of artificial islands, installations and structures.

CRD RSRP.006/03



comment Hamad Airport

International


ADR.AR.A.015

NPA text

1. Acceptable means of compliance (AMC) and certification specifications (CSs) published by Authority or, when acceptable to the Authority, published by EASA, standard making bodies or qualified entities, may be used to establish compliance with the Civil Aviation Law and this Regulation. When AMC or CS are complied with, the related requirements of this Regulation are presumed to be met. 2. AMC and CS published by the Authority have precedence on any other alternative AMC or CS. 3. Alternative means of compliance or technical specifications may be proposed by the applicant to establish compliance with the Civil Aviation Law and this Regulation. …. 7. When the Authority itself publishes, or finds suitable to achieve compliance with the Civil Aviation law and this Regulation, the acceptable means of compliance or certification specifications mentioned in 1, the Authority shall make these AMCs or CSs known through electronic means, to all involved organisations and persons.

Comment

“published by Authority” It is understood that AMC is not published by Authority at this stage. “published by EASA”. It is understood that QCAR will not be legally connected with EASA.


No alternative text proposed by commentator.

Response Accepted

Details of response

1. Indeed the Authorty has not published any AMC/GM in NPA RSRP.006/03 as of 01 March 2017, but it is intend to publish a new NPA containing at least AMC/GM applicable to international aerodromes, by the end of May 2017.

2. Reference to EASA and others removed from paragraph 1 of ADR.AR.A.015, and instead inserted in par. 3 (i.e. discretion of the applicant)

Resulting text

1. Acceptable means of compliance (AMC) and certification specifications (CSs) published by the Authority Authority or, when acceptable to the Authority, published by EASA, standard making bodies or qualified entities, may be used to establish compliance with the Civil Aviation Law and this Regulation. When AMC or CS are complied with, the related requirements of this Regulation are presumed to be met. 2. AMC and CS published by the Authority have precedence on any other alternative AMC or CS. 3. Alternative means of compliance or technical specifications may be proposed by the applicant to establish compliance with the Civil Aviation Law and this Regulation, including , when acceptable to the Authority, those published by other authorities, standard making bodies or qualified entities. …. 7. When the Authority itself publishes, or finds suitable to achieve compliance with the Civil Aviation law and this Regulation, the acceptable means of compliance or certification specifications mentioned in 1 3, the Authority shall make these AMCs or CSs known through electronic means, to all involved organisations and persons.




ADR.AR.C.025

NPA text (a) the Authority shall prescribe special detailed technical specifications, named special conditions, for an international aerodrome, if the related certification specifications issued by

CRD RSRP.006/03


the the Authority referred to in point ADR.AR.C.020(a) are inadequate or inappropriate, to ensure safety and regularity of operations, because:

Comment Repeated word in line 2: The the


Remove repeated word

Response Accepted

Details of response

Repetition removed.

Resulting text

(a) the Authority shall prescribe special detailed technical specifications, named special conditions, for an international aerodrome, if the related certification specifications issued by the the Authority referred to in point ADR.AR.C.020(a) are inadequate or inappropriate, to ensure safety and regularity of operations, because:


comment Hamad Airport International


ADR.AR.C.040 (a)2

NPA text

(a) Upon receiving an application for a change, in accordance with ADR.OR.B.040, that requires prior approval, the Authority shall assess the application and, if relevant, notify the aerodrome operator of:

…

Comment It is expected that a specific format be made available by he Authority for such applications.



Response Partally accepted

Details of response

Indeed the Authority intends to develop a procedure for assessment and possible approval of changes, which will include also the application form. The same applies to ADR.AR.D.040(a). However, also ADR.OR.C.040 should be mentioned.

Resulting text

(a) Upon receiving an application for a change, in accordance with ADR.OR.B.040 or ADR.OR.C.040, that requires prior approval, the Authority shall assess the application and, if relevant, notify the aerodrome operator of:




ADR.AR.D.040 (c)

NPA text (c) If the approved change affects the Aeronautical Information, the Authority shall instruct the provider of Aeronautical Information to amend it.

Comment (c) There may be such changes which the Aerodrome Operator would like to inform AIS directly, with information to the Authority.



Response Acceped

Details of response

Paragraph rephrased following the comment, with the aim of streamlining the process.

Resulting text (c) If the approved change affects the Aeronautical Information, after approval by the Authority Authority, the aerodrome operator shall instruct convey the approved change to the provider of Aeronautical Information to amend it.

2 The comments from HAI I applicable to ADR.AR.C.040, not to ADR.OR.D.040, since the former belongs to subpart C (oversight of international aerodromes) and the latter to subpart D (oversight of domestic aerodroes subject to declaration, nut not certification).

CRD RSRP.006/03





ADR.AR.D.050

NPA text 050 (a) he Authority for oversight in accordance with ADR.AR.D.010 and ADR.AR.D.020 shall have a system to analyse findings for their safety significance.

Comment It would be better to define which area of the Authority will analyse findings


Could the Authority define which area will analyse findings?

Safety Data or AGA etc.

Response Noted

Details of response

Indeed AGA will coordinate as necessary


Comment No.

16 Originator of



ADR.AR.D.050

NPA text

ADR.D.050 (b) (c) & 4 (e)

(b) A level 1 finding shall be issued by the Authority when any significant non-compliance is detected with the applicable requirements of Civil Aviation Law and this Regulation, with the aerodrome operator’s or services provider’s procedures and manuals or with the content of a declaration which lowers safety or seriously endangers safety. The level 1 finding shall include: ….

Comment No definition of Observations like Level 1 & 2 Findings on page 37


Define Observations on Page 37 after Level 2 Findings.

Response Accepted

Details of response

Observations will now be clarified in paragraph (e) of ADR.AR.D.050,

Resulting text (e) For those cases not requiring level 1 or level 2 findings, the Authority may issue observations, which cover items that may affect safety or which the aerodrome operator may need to consider for continuous improvement.


comment



ADR.AR.E.010

NPA text

(a) Upon receiving an application for registration from an operator of an aerodrome, heliport or helideck only used by the owner or by a person specifically authorised by the owner, the Authority shall ….

(b) … (e) Once the information is complete, the Authority shall verify:

…. (2) list of entities, companies or natural persons authorised by the owner to use the

aerodrome.

Comment Domestic: Definition, not open to public; However, is a charter operation considered as being open to public as would be the case with helicopter operation conducted on behalf of a single entity?


None


Details of response

The itent is that only natural persons, legal entities or operators authorised by the owner would be allowed to use a facility not open to public use.

CRD RSRP.006/03


If the charter helicopter operator is authorised by the owner, the helicopter operator would not need to request further authorisation for its passengers. The text of letter (a) may however be made clearer

Resulting text

(a) Upon receiving an application for registration from an operator of an aerodrome, heliport or helideck only used by the owner, or by a natural person or by an aircraft operator specifically authorised by the owner, the Authority shall ….


comment



ADR.AR.E.010

NPA text

(a) Upon receiving an application for registration from an operator of an aerodrome, heliport or helideck only used by the owner or by a person specifically authorised by the owner, the Authority shall ….

Comment

Helideck It is considered as not open to the public. As it is “not open to the public” then are passengers that are contractors to the charterer effectively considered?


None

Response Noted

Details of response

The helideck may or may not be open to public use, depending on the decision of the owner. In the former case it would be published in the AIP and any civil helicopter operator may plan to land there, following the instructions in the AIP. In the latter case, the owner will authorise only specific helicopter operators to land there, and the facility would not be published in AIP. The agreement between the helideck operator and the helicopter operator would specify the names or the categories (e.g. employees of the oil company) of passengers eligible for transport.

Resulting text No change to the proposed text is deemed necessary on the basis of this comment




ADR.OR.B.015

NPA text (b) The applicant shall provide the Authority with the following:

(2) …. (iii) safeguarding map

Comment Safeguarding map is not made by the Aerodrome Operator. If found as acceptable, AIS office and their surveying contractor, shall report to the Aerodrome Operator; thus reporting link shall be: Surveyor – AIS – AO - Authority.



Response Accepted

Details of response

Respective responsibilities defined in Article 8 of cover Regulation (see response to comment 13 above). In addition ADR.OR.B.015 (b)(2)(iii) amended, to clarify that the safeguarding map is not produced by the aerodrome operator, but nevertheless the aerodrome operator should be aware of this map and its content, and continually monitor the situation.

Resulting text (iii) copy of the safeguarding map obtained on the basis of Article 9.3.

CRD RSRP.006/03




International


ADR.OR.B.025 (a)(1)(ii)

NPA text (a)(1)(ii) that the aerodrome, as well as its obstacle limitation and protection surfaces and other areas associated with the aerodrome, have no features or characteristics making it unsafe for operation

Comment

Aerodrome Operator has established procedures to safeguard the area within the aerodrome boundary only. It is recommended that the safeguarding function remains with Authority as this function is established and in a mature stage of its development.



Response Accepted

Details of response

Paragraph (a)(1)(ii) shortened and made more generic, to exclude responsibility of the operator in drawing the safeguarding map. Responsibilities of the aerodrome operator for monitoring are in Annex V, Subpart B and they extend beyond the aerodrome boundary.

Resulting text (ii) that the aerodrome, as well as its obstacle limitation and protection surfaces and other areas associated with the aerodrome, have has no features or characteristics making it unsafe for operation




ADR.OR.B.025 (a)(1)(iii)

NPA text (a)(1)(iii) that the instrument flight procedures of the aerodrome have been approved.

Comment (iii) Aerodrome Operator may not have the necessary abilities to approve the instrument flight procedures.



Response Accepted

Details of response

The statement by the commentator is correct. The aerodrome operator has the responsibility for ensuring that its instrument flight procedures, have been validated, approved, remain current, and are published within the AIP. This activity may be subcontracted to a third party specialist provider of such services

Resulting text (iii) that the instrument flight procedures of the aerodrome have been approved by the Authority, directly or through a service provider.


comment



ADR.OR.B.040

NPA text (d) Changes not requiring prior approval shall be managed and notified to the Authority as

defined in the procedure approved by the Authority in accordance with ADR.AR.C.035(h).

Comment

Minor changes What is the definition of minor change? Not defined in Qatar, needs to be defined. Adopt the prior approval procedure established for OPS Define in the regulation what is a major change. The rest are then a minor change.


None

Response Noted

Details of response

The list of changes requiring prior approval (de facto ‘major’) will indeed be covered by AMC1 and GM1 to ADR.OR.B.040 (a) and (b).


CRD RSRP.006/03





ADR.OR.C.005 (b)

NPA text

(b) The aerodrome operator shall ensure directly, or coordinate through arrangements as required with the accountable entities providing the following services:

(1) the provision of air navigation services appropriate to the level of traffic and the operating conditions at the aerodrome; and (2) the design and maintenance of the flight procedures, in accordance with the applicable requirements.

Comment

HIA will enter into a SLA with the ANSP as a means of compliance with this requirement. The set up of SLA with the ANSP or the establishment of any other organisational set up to meet this requirement would require an extension for implementation beyond 2018. In accordance with EU practice, a time limit of up to 3 years (May 2020) is considered to be reasonable.




Details of response

The transition period in the EU was linked to the fact that some EU member States did have to certify 100 aerodromes, which of course required extensive effort from the national Authority. On the contrary in Qatar there are presently only two international aerodromes serving scheduled commercial traffic. Hwever the Authority will move the deadline to 31 May 2018 insteaf of 30th April 2018 offering one month for a robust coordination mechanism between the Regulator, AND and HIA, to be established. Even if some essential aerodrome services are delivered by specific Departments of the Authority, the aerodrome operator remains the primary responsible body to manage the safe integration of all services and activities at the aerodrome.

Resulting text

Paragraph 1 of Article 7 is modified as follows: 1. Certificates issued by the Authority for international aerodromes prior to 30 April 2017 on the basis of previous regulations shall remain valid until they are issued in accordance with this Article, before 30 April 31 May 2018.

Comment No. 47 Originator

of comment


Affected NPA

paragraph ADR.OR.C.005 (b)

NPA text

The aerodrome operator shall ensure directly, or coordinate through arrangements as required with the accountable entities providing the following services: (1) the provision of air navigation services appropriate to the level of traffic and the operating

conditions at the aerodrome; and (2) the design and maintenance of the flight procedures, in accordance with the applicable

requirements.

Comment Consultation with Authority and Authority/AND should agree on the additional services to be listed in this requirement, e.g. aerodrome data survey, apron management, aerodrome ground lighting, aerodrome rescue and fire fighting (see comment 35 above)


Should be rewritten after new consultation and agreement.

Response Accepted

Details of response

Additional services added to the list in ADR.OR.C.005 (b).

Resulting text

The aerodrome operator shall ensure directly, or coordinate through arrangements as required with the related accountable entities, that providing the following services are provided at the aerodrome: (1) the provision of air navigation services appropriate to the level of traffic and the operating

conditions at the aerodrome, including air traffic services, aeronautical data and information, meteorological services, aeronatucal communications, radio-navigation and air traffic surveillance; and

(2) the design and maintenance of the flight procedures, in accordance with the applicable requirements;

CRD RSRP.006/03


(3) apron management; (4) aeronautical ground lighting; (5) aerodrome rescue and firefigting services; (6) ground handling; and (7) any other service relavent for the safety of aviation operations at the arodrome.




ADR.OR.C.015 (b)(6)

NPA text (b) The applicant shall provide the Authority with the following:

(6) a copy of the aerodrome operator manual.

Comment HIA understands that the Aerodrome operator manual is an extension of SMS document (ADR.OR.H.010 para a) and c)



Response Noted

Details of response

The SMS forms part of the aerodrome operator manual, which details the “soft” requirements of the operation, i.e. Org charts, centralised functions, SMS, Security Manual. The Aerodrome Manual will be specific to each aerodrome and will cover the infrastrcure and facilities provided, the “hard requirements” The minimum content of the manuals will be detailed in AMC/GM to Part OR.H.



comment



ADR.OR.C.060

NPA text (c) The reports referred to in points (a) and (b) shall be made in a form and manner

established by the Authority and contain all pertinent information about the condition known to the aerodrome operator.

Comment Safety data: Are data protection provisions established?


None

Response Accepted

Details of response

Although any Authority Regulation on occurrence reporting will apply, including protection of safety and reporter’s data, text of letter (c) in ADR.OR.C.060 may be clearer on this point. Consequently, ADR.OR.F.060 (c) for domestic aerodromes and ADR.OR.G.060 (c) for aerodromes not open to public use should be amended.

Resulting text

ADR.OR.C.060 (c) The reports referred to in points (a) and (b) shall be made in a form and manner established by the Authority, including protection of safety information and reporter’s data, and contain all pertinent information about the condition known to the aerodrome operator. ADR.OR.F.060 (c) The reports referred to in points (a) and (b) shall be made in a form and manner established by the Authority, including protection of safety information and reporter’s data, and contain all pertinent information about the condition known to the aerodrome operator or the service provider. ADR.OR.G.060 (c) The reports referred to in points (a) and (b) shall be made in a form and manner established by the Authority, including protection of safety information and reporter’s data, and contain all pertinent information about the condition known to the aerodrome operator or the service provider.


of comment


Affected NPA

paragraph ADR.OR.C.070 (a)(1)

NPA text (1) personnel involved in the operation, rescue and firefighting, and maintenance of the aerodrome;

Comment For personnel under its responsibility only (see comment 35 above)

CRD RSRP.006/03



(1) personnel involved in the operation, rescue and firefighting, and maintenance of the aerodrome when under its responsibility;

Response Accepted

Details of response

ADR.OR.C.070 (a)(1) modified as proposed by the commentator.

Resulting text (1) personnel under its direct responsibility and involved in the operation, rescue and firefighting, and maintenance of the aerodrome;




ADR.OR.D.005 (b)(8)

NPA text

(b)(8) a safety training programme that ensures that personnel involved in the operation, rescue and firefighting, maintenance and management of the aerodrome are trained and competent to perform the safety management system duties;

Comment

ARFF services are provided by Authority and ARFF is operationally, functionally and administratively managed by the Authority. HIA agrees to this requirement in principle; however implementation of this requirement may take more time beyond 2018. In accordance with EU practice, a time limit of up to 3 years (May 2020) is considered to be reasonable.




Details of response

The aerodrome operator has prime responsibility for the safety management of the total aviation system at the aerodrome, in line with ICAO provisions in Annex 19 and in PANS/ADR (Doc 9981). Irrespective of whether an essential aerodrome service is provided by a third party, the aerodrome operator is responsible for ensuring that the SMS of third parties is harmonised with the SMS of the aerodrome operator. See also response to comment 24 above.

Resulting text No change to the proposed text is deemed necessary on the basis of this comment, in addition to he text resulting from comment 24 above.




ADR.OR.D.007

NPA text

(a) As part of its management system, the aerodrome operator of an international aerodrome shall implement and maintain a quality management system covering:

…

Comment The quality management system reqirement of AIS shall be part of an SLA. We consider hat fulfilment of AMC from EASA will satisfy the quality requirement.



Response Noted

Details of response

It is correct that some data will be directly acquired by AIS. But is is also true that some information to be published n AIP will be originated by the aerodrome operator. In any case indeed that AMC/GM toADR.OR.D.007 are modelled on the EASA equivalent provisions.



of comment


Affected NPA

paragraph ADR.OR.D.007

NPA text

(a) As part of its management system, the aerodrome operator of an international aerodrome shall implement and maintain a quality management system covering:

(1) its aeronautical data activities; and

(2) its aeronautical information provision activities.

CRD RSRP.006/03


(b) The aerodrome operator shall define procedures for meeting the safety and security management objectives with respect to:

(1) aeronautical data activities; and

(2) aeronautical information provision activities.

Comment In Qatar the aeronautical data and information, as in most of the countries in the world, are under Authority/AND. Service Level Agreement (SLA) between the parties exists.


(a) As part of its management system and when in charge of this activity, the aerodrome operator …

Response Accepted

Details of response

Indeed the intention of the draft text was as proposed by the commentator. The proposed additional words are inserted to enhance clarity.

Resulting text As part of its management system and when in charge of this activity, the aerodrome operator of an international aerodrome shall implement and maintain a quality management system covering:


of comment


Affected NPA


NPA text

The aerodrome operator of one or more international aerodromes, shall appoint an accountable manager, who has the Authority for ensuring that all activities can be financed and carried out in accordance with the applicable requirements. The accountable manager shall be responsible for establishing and maintaining an effective management system covering all international aerodromes under the responsibility of the operator.

Comment only apply to the services and operations it is responsible for comment is valid for the full requirement


… who has the Authority for ensuring that all activities under its responsibility can be financed and carried out …

Response Accepted

Details of response

The proposed additional words are inserted to increase clarity on respective accountabilities of different managers.

Resulting text

The aerodrome operator of one or more international aerodromes, shall appoint an accountable manager, who has the Authority for ensuring that all activities under its responsibility can be financed and carried out in accordance with the applicable requirements. The accountable manager shall be responsible for establishing and maintaining an effective management system covering all international aerodromes under the responsibility of the operator.


of comment


Affected NPA


NPA text The aerodrome operator of one or more international aerodromes shall establish and implement a training programme for personnel involved in the operation, maintenance and management of the aerodromes.

Comment only apply to the services and operations it is responsible for. comment is valid for the full requirement


… shall establish and implement a training programme for personnel involved in the operation, maintenance and management of the aerodromes and for whom it is responsible for.


Details of response

Intent of the comment fully agreed. However wording adjusted toclarify that the aerodrome operator may remain accountable also for training of personnel employed by other organisations (e.g. personnel authorised to unescorted access to the air side).

CRD RSRP.006/03


Resulting text The aerodrome operator of one or more international aerodromes shall establish and implement a directly or through the arrangements in ADR.OR.C.005 (b), training programmes for personnel involved in the operation, maintenance and management of the aerodromes.


of comment


Affected NPA

paragraph ADR.OR.D.020 (a)

NPA text The aerodrome operator shall ensure that adequate and appropriate facilities are available to its personnel or personnel employed by parties with whom it has contracted for the provision of aerodrome operational and maintenance services.

Comment only apply to the services and operations it is responsible for comment is valid for the full requirement


... by parties with whom it has contracted for the provision of aerodrome operational and maintenance services it is responsible for.


Details of response

Indeed the wording of this can be improved. However the aerodrome operator shall ensure that proper facilities are available not only to its personnel and its contractors, but to all service providers listed in ADR.OR.C.005 (b), such as, bu not limited, to e.g. power supply to ILS transmitters and water to RFFS.

Resulting text

The aerodrome operator shall ensure that adequate and appropriate facilities are available to its personnel or personnel employed by parties with whom it has contracted for the provision of aerodrome operational and maintenance services and also to personnel of the service providers listed in ADR.OR.C.005 (b).


of comment

Franz Sammueller Authority/AND [email protected] Kevin Cooper Authority/AND [email protected] Bernard Lucat Authority/AND [email protected]

Affected NPA


NPA text

a) establish, lead and implement programmes …

(b) establish an Aerodrome Safety Team …

Comment

Best practices show that it is generally under the Air Navigation Services provider responsibility. Is the Aerodrome Safety Team addressing same issues as the Runway Safety Team? This requirement should have been subject of a more intensive consultation of all stakeholders!


(a) establish or contribute to the implementation of programmes …

(b) establish or contribute to an Aerodrome Safety Team


Details of response

1. As clarified in reponse to comment 35, paragraph 3.3.2.1 f) of the second edition of Annex 19 to the Chcago Convention, mandates safety management to be implemented by operators of aerodromes certified in accordance with Annex 14 (i.e. international).

2. That standard in Annex 19 is amplified by paragraph 2.4.2.2 of the PANS-ADR: “The aerodrome operator should ensure that all users of the aerodrome, including ground-handling agencies and other organizations that perform activities independently at the aerodrome in relation to flight or aircraft handling, comply with the safety requirements of the aerodrome operator. The aerodrome operator monitors such compliance.”

3. These ICAO provisions are transposed in Article 4 of the cover Regulation QCAR ADR.

CRD RSRP.006/03


4. All service providers shall then participate to the Aerodrome Safety team established by the aerodrome operator.

5. AMC will clarify that this Team may establish specialised groups, e.g. for for runway safety.

6. The requirements in QCAR ADR do not exempt cerified service providers to establish their own safety management, on the basis of respectively applicable rules.



comment



ADR.OR.F.015

NPA text (b)(3) any deviations from the identified applicable certification specifications established by

the Authority;

Comment Declarations: Processes required as part of the system.Is the basis of the oversight documented?


None

Response Noted

Details of response

Yes. ADR.OR.F.015 specifies information to be attached to the declaration, including any deviations from the identified applicable certification specifications, which indeed constitutes a basis for oversight.





ADR.OR.H.030 (b)(5)

NPA text (b)(5) Description of the management system and related processes, for safety, security, quality and environment.

Comment

In order to satisfy this requirement, the legal aspects of environment management system received by Authority from Ministry of Environmet sall be disseminated to the AO, otherwise AO recommends not to include Environment in the Aerodrome Manual. QMS should be excluded as no further details on a QMS requirement are provided in the regulation.




Details of response

Quality management (alias compliance monitoring) is required by ADR.OR.D.005 (b) (11). Eviromental issues shall in any case be managed by the aerodrome operator on the basis of applicable regulations. It is not necessary to include this in the manual.

Resulting text (b)(5) Description of the management system and related processes, for safety, security and quality and environment.


of comment


Affected NPA

paragraph ADR.OPS Subpart A

NPA text All requirements

Comment

This specific subpart demonstrate the need to have a set of requirements addressing Service Level Agreement (SLA) between the aerodrome operator and other services providers, e.g. AIM, CNS, etc … In the case of Qatar data survey is conducted under Authority/AND responsibility and NAVAIDS operation and maintenance, as for most of aerodromes in the world, are also under the responsibility of the ANS provider, i.e. Authority/AND. As for the other Subparts of this Annex a requirement 001 is missing for Subpart A.


Proposed new requirement ADR.OPS.A.001: The services under Subpart A of this Annex shall be provided by the aerodrome operator directly or indirectly, respectively at international aerodromes, domestic aerodromes open to public use. When services addressed under Subpart A are not provided directly by the

CRD RSRP.006/03


aerodrome operator it shall establish Service Level Agreements (SLA) with other services providers defining the conditions under which the services shall be delivered and monitored. The subsequent requirements of Subpart A respectively apply to other services providers as part of the aerodrome certification process. "aerodrome operator … determine, document and maintain data relevant to the aerodrome and available services under its responsibility" See further comments below

Response Accepted

Details of response

New rule ADR.OPS.A.001 added along the lines poposed by the commentator. ADR.OPS.A.005 (a) also modified.

Resulting text

ADR.OPS.A.001 Provision of services (a) The services under Subpart A of this Annex shall be provided by the aerodrome

operator directly or through the service providers listed in ADR.OR.C.005, respectively at international aerodromes and domestic aerodromes open to public use.

(b) When services addressed in this part-AR.OPS are not provided directly by the aerodrome operator, it shall establish Service Level Agreements (SLA) with other services providers defining the conditions under which the services shall be delivered and monitored, as per ADR.OR.C.005.

ADR.OPS.A.005

(a) determine, document and maintain data under its responsibility relevant to the aerodrome and available services;


of comment


Affected NPA

paragraph ADR.OPS.A.015 (a)

NPA text

(a) To ensure that aeronautical information services providers obtain information to enable them to provide up-to-date pre-flight information and to meet the need for in-flight information, the aerodrome operator of an international aerodrome or of a domestic aerodrome open to public use, shall make arrangements to report to the relevant aeronautical information service providers, with a minimum of delay, the following:

(1) information on the aerodrome conditions, disabled aircraft removal, rescue and firefighting and visual approach slope indicator systems;

(2) the operational status of associated facilities, services and navigational aids at the aerodrome;

(3) any other information considered to be of operational significance.

Comment NAVAIDS are part of CNS under Authority?AND responsibility


… and navigational aids, when under its responsibility, at the aerodrome.

Response Accepted

Details of response

Intent of the comment shared. Text of (a) modified.

Resulting text

(a) To ensure that aeronautical information services providers obtain information to enable them to provide up-to-date pre-flight information and to meet the need for in-flight information, the aerodrome operator of an international aerodrome or of a domestic aerodrome open to public use, shall make establish internal procedures or arrangements with service providers to report to the relevant aeronautical information service providers, with a minimum of delay, the following: ….

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of comment


Affected NPA

paragraph ADR.OPS.A.015 (b)

NPA text Before introducing changes to the air navigation system, the aerodrome operator shall take due account of the time needed by the relevant aeronautical information services for the preparation, production and issue of relevant material for promulgation.

Comment Refer to comment 53 above.


Before introducing changes to aerodrome facilities or services it is responsible for, the aerodrome operator …

Response Accepted

Details of response

ADR.OPS.A.015 (b) modified to capture the ntent of the comment.

Resulting text

Before introducing changes to the air navigation system, infrastrucutres, facilities or services under its managerial control, the aerodrome operator shall take due account of the time needed by the relevant aeronautical information services for the preparation, production and issue of relevant material for promulgation.


of comment

Franz Sammueller Authority/AND [email protected] Bernard Carter Authority/AND/ARFFS [email protected] Bernard Lucat Authority/AND [email protected]

Affected NPA

paragraph ADR.OPS.B.001

NPA text The services under Subpart B of this Annex shall be provided by the aerodrome operator directly or indirectly, respectively at international aerodromes, domestic aerodromes open to public use or at aerodromes not open to public use, including heliports and helidecks.

Comment As it is the case in Qatar, ARFFS, CNS and ATS services are provided by Authority/AND. As indicated in comment 53 above SLA's shall be developed between the aerodrome operator and other services providers.


… shall be provided by the aerodrome operator directly or indirectly, … and helidecks. When services addressed under Subpart B are not provided directly by the aerodrome operator it shall establish Service Level Agreements (SLA) with other services providers defining the conditions under which the services shall be delivered and monitored. The subsequent requirements of Subpart B respectively apply to other services providers as part of the aerodrome certification process.

Response Accepted

Details of response

Two more paragraphs added to ADR.OPS.B.001. For consistency, similar rule ADR.OPS.C.001 added to subpart C.

Resulting text

(a) The services under Subpart B of this Annex shall be provided by the aerodrome operator directly or indirectly, respectively at international aerodromes, domestic aerodromes open to public use or at aerodromes not open to public use, including heliports and helidecks.

(b) When services addressed under this Subpart B are not provided directly by the aerodrome operator but by a different service provider organisation, both parties shall establish a Service Level Agreement (SLA) defining the conditions under which the services shall be delivered and monitored.

(c) The subsequent requirements of this Subpart B respectively apply as defined in th SLA.

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International

Affected NPA

paragraph ADR.OPS.B.010

NPA text

(a) The aerodrome operator shall ensure that:

(1) aerodrome rescue and firefighting facilities, equipment and services are provided;

(2) adequate equipment, fire extinguishing agents and sufficient personnel are available in a timely manner;

(3) rescue and firefighting personnel are properly trained, equipped and qualified to operate in the aerodrome environment; and

(4) rescue and firefighting personnel potentially required to act in aviation emergencies demonstrate their medical fitness to execute their functions satisfactorily, taking into account the type of activity.

(b) The aerodrome operator shall establish and implement a training programme for persons involved in rescue and firefighting services of the aerodrome;

(c) The aerodrome operator shall implement proficiency checks at adequate intervals to ensure continued competence of rescue and firefighting personnel;

(d) The aerodrome operator shall ensure that:

(1) adequately qualified and experienced instructors and assessors for the implementation of the training programme are used; and

(2) suitable facilities and means are used for the provision of the training.

(e) The aerodrome operator shall:

(1) maintain appropriate qualification, training and proficiency check records to demonstrate compliance with this requirement;

(2) on request, make such records available to its personnel concerned; and (3) if a person is employed by another employer, on request, make such

records of that person available to that new employer.

(f) Temporary reduction of the level of protection of the aerodrome’s rescue and firefighting services, due to unforeseen circumstances, shall not require prior approval by the Authority.

Comment Operator agrees in principle but extension of timeline beyond 2018 is required in order to enter into a SLA or to establish other suitable organisational arrangements to met this requirement as RFFS is currently provided by the Authority.




Details of response

See response to comment 24 above.



of comment

Franz Sammueller Authority/AND [email protected] Bernard Lucat Authority/AND [email protected]

Affected NPA

paragraph ADR.OPS.C.005

NPA text

The aerodrome operator of an international aerodrome shall establish and implement a maintenance programme, including preventive maintenance where appropriate, to maintain aerodrome facilities so that they comply with the Civil Aviation Law, this Regulation and the aerodrome certification basis.

Comment As already mentioned not all facilities and equipment are under the aerodrome operator responsibility.

CRD RSRP.006/03



The aerodrome operator … shall establish and implement a maintenance programme for facilities and equipment under its responsibility, …

Response Partialy accepted

Details of response

The aerodrome operator has overall accountability to ensure that all acilities (e.g. aeronautical ground lights) are properly maintained, directly or through arrangements with service providers. Text adjusted accordingly.

Resulting text

The aerodrome operator of an international aerodrome shall establish and implement, directly or through the arrangements in ADR.OR.C.005, a maintenance programme, including preventive maintenance where appropriate, to maintain aerodrome facilities so that they comply with the Civil Aviation Law, this Regulation and the aerodrome certification basis.



International


ADR.OPS.C.015

NPA text

The aerodrome operator shall establish and ensure the implementation of a system of corrective and preventive maintenance of visual aids and electrical systems to ensure lighting and marking system availability, reliability and compliance.

Comment

We agree in principle to this greement, howeve timeline for implementation needs to be extended beyond 2018 as maintenance of isual aids and electrical system is currently performed by Authority. Extended time is required to either enter into a SLA with Authority or to establish other organisational arrangement to meet tis requirement. In accordance with the EU practice, a time limit of up to 3 years (May 2020) is considered to be reasonable.




Details of response


Resulting text See text resulting after comment 24.


of comment


Affected NPA

paragraph ADR.OPS.D.001

NPA text The requirements under Subpart D of this Annex shall be fulfilled at international aerodrome, and, when explicitly indicated, at domestic aerodromes open to public use, by the aerodrome operator directly or indirectly.

Comment

Same comment as other Subparts. It is intreresting to note that for the first time (and last) the requirement ADR.OR.D.025 (b) seems indicating that apron management services might be provided by air navigation services (as it is the reviewers' opinion that it might not be done by the commercial air transport operator)


… by the aerodrome operator directly or indirectly. When apron management services addressed under Subpart D are not provided directly by the aerodrome operator it shall establish Service Level Agreements (SLA) with other services providers defining the conditions under which the services shall be delivered and monitored. The subsequent requirements of Subpart D respectively apply to other services providers as part of the aerodrome certification process.

Response Accepted

Details of response

Two more paragraphs added to ADR.OPS.D.001 as proposed by commentator.

CRD RSRP.006/03


Resulting text

(a) The requirements under Subpart D of this Annex shall be fulfilled at international aerodrome, and, when explicitly indicated, at domestic aerodromes open to public use, by the aerodrome operator directly or indirectly.

(b) When apron management services addressed under this Subpart D are not provided directly by the aerodrome operator but by a different service provider organisation, both parties shall establish a Service Level Agreement (SLA) defining the conditions under which the services shall be delivered and monitored.

(c) The subsequent requirements of this Subpart D respectively apply as defined in th SLA.



International

Affected NPA

paragraph ADR.OPS.D.005 to D020

NPA text

ADR.OPS.D.005 Apron management

The aerodrome operator shall ensure that procedures are in place for the management of operations on the apron at international aerodromes.

ADR.OPS.D.010 Management of aircraft movement on the apron

The aerodrome operator shall ensure that means and procedures are in place for the management of aircraft movements on the apron at an international aerodrome and at a domestic aerodrome open to public use, in order to prevent collisions between aircraft, and between aircraft and obstacles, vehicles and persons.

ADR.OPS.D.015 Coordination of aircraft entry to/exit from the apron

The aerodrome operator shall ensure that entry of aircraft to, and exit of aircraft from, the apron is coordinated with the air traffic services provider, when aircraft movement on the apron is not managed by the air traffic services provider.

ADR.OPS.D.020 Apron management services boundaries

The aerodrome operator, in cooperation with the air traffic services provider, shall define and provide for publication in the Aeronautical Information Publication of the boundaries between different areas of responsibility.

Comment The mentioned services are being provided by the ANSP (Authority).



Response Noted

Details of response

The key verb in these requirement is ‘to ensure’ meaning that the aerodrome operator shall have evidence that apron management is either directly provided by is organisation, or made available through arrangements with other sevice providers.Details of respective roles and coordination procedures, are left to a SLA between the aerodrome operator and the service provider.


CRD RSRP.006/03



of comment


Affected NPA

paragraph

ADR.OPS Subpart E

NPA text New text

Comment In line with comments above a new requirement should be added


Proposed new requirement ADR.OPS.E.001 Scope: The services under Subpart E of this Annex shall be provided by the aerodrome operator directly or indirectly, respectively at international aerodromes, domestic aerodromes open to public use. When services addressed under Subpart E are not provided directly by the aerodrome operator it shall establish Service Level Agreements (SLA) with other services providers defining the conditions under which the services shall be delivered and monitored. The subsequent requirements of Subpart E respectively apply to other services providers as part of the aerodrome certification process.

Response Accepted

Details of response

New rule ADR.OPS.E.001 added as proposed by commentator

Resulting text

ADR.OPS.E.001 Provsion of services (a) The services under Subpart E of this Annex shall be provided by the aerodrome

operator directly or indirectly, respectively at international aerodromes, domestic aerodromes open to public use.

(b) When services addressed under Subpart E are not provided directly by the aerodrome operator it shall establish Service Level Agreements (SLA) with other service providers defining the conditions under which the services shall be delivered and monitored.

(c) The subsequent requirements of Subpart E respectively apply as defined in the SLA.



International


ADR.OPS.F.001 (b)(6)

NPA text

(b) Without prejudice to additional ground handling services of administrative, facilitation or commercial nature, the following ground handling services shall be safely provided at international aerodromes: …

(6) equipment and service for 'FOLLOW ME', push-back or towing, including towing to/from hangars or between maintenance and operations areas;

Comment Follow me should fall under apron management responsibilities describd in subpart E; not under responsibility of ground handling under subpart F.



Response Accepted

Details of response

FOLLOW ME removed from requirements for groud handling

Resulting text (6) equipment and service for 'FOLLOW ME', push-back or towing, including towing to/from hangars or between maintenance and operations areas;


comment



ADR.OPS.F.002

NPA text Written agreements between the aerodrome operator and the providers of ground handling services shall ensure that arrangements are in place for the safe management of such services at international aerodromes

Comment Ground handling. SMS obligations need to be documented

Alternative text proposed

None

CRD RSRP.006/03


by commentator

Response Accepted

Details of response

Indeed. The intention expressed by the commentator is fully shared and in fact already covered by ADR.OPS.F.002 and also by ADR.OR.D.005 (b)(4). For sake of clarity explicit reference to the latter is included in ADR.OPS.F.002.

Resulting text Written agreements between the aerodrome operator and the providers of ground handling services shall ensure that arrangements are in place for the safe management of such services at international aerodromes, in compliance with ADR.OR.D.005 (b)(4).



International


ADR.SRP.A.001

NPA text Scope (a) and (b) “domes” and “the Authority shall surroundings”

Comment Aerodrome Operator cannot comment this article at this stage as due to grammatical errors the meaning is not clear. We reserve the right to submit comments pertaining to this article at a later stage once submitted after grammatical revision.



Response Noted

Details of response

Indeed the text published in the pdf version was not understandable. However the text was clear and correct in the background original file. This text does not contain any requirement addressing the aerodrome operator. For sake of clarity the text is reproduced two lines below.

Resulting text

The original (uncorrupted) text remains unchanged: (a) The requirements of this Annex shall be fulfilled to protect international

aerodromes, domestic aerodromes open to public use and registered aerodromes, heliports and helidecks not open to public use, from activities and constructions in their surroundings.

(b) Without prejudice to additional hazards which the Authority may identify, the Authority shall administer safeguards to protect aerodromes from the following activities and constructions in their surroundings: ….


of comment

Pamela Erice AIS/Air Navigation [email protected]

Affected NPA

paragraph

Annex V ADR.SRP Subpart A

NPA text All text

Comment Poor formatting, text missing/cut on the right hand side and numerous typos. Difficult to anticipate what is missing


None

Response Noted

Details of response


Resulting text See resulting text in comment 34 above.

CRD RSRP.006/03



of comment


Affected NPA

paragraph ADR.SRP.A.001 (a)

NPA text Aerodrome Surroundings

Comment The scope should define or explain what is meant. Is it limited to the OLS or beyond?


None


Details of response

Scope already defined in paragraph (c) of this rule, with reference to obstacle limitation surfaces.



of comment


Affected NPA

paragraph

ADR.SRP.A.001 (c)(3)

NPA text (c)(3) outside the perimeter of the surfaces in (1) but having a height above surface level of 50 m or greater;

Comment Missing rest of the sentence. It was previously 45 m over all territory is there a rationale for the change?


None

Response Accepted

Details of response

Indeed current QCAR-ADR (issue 5, dated May 2014) prescribe lighting of objects with a height less than 45m above ground level: ‘6.2.3.19 Low-intensity obstacle lights, Type A or B, shall be used where the object is a less extensive one and its height above the surrounding ground is less than 45 m’ For sake of consistency the same value is inserted (instead of 50 m) into ADR.SRP.A.001.

Resulting text (c)(3) outside the perimeter of the surfaces in (1) but having a height above surface level of 50 m 45 m or greater;


of comment

Franz Sammueller Authority/AND [email protected] Kevin Cooper Authority/AND [email protected]

Affected NPA

paragraph

ADR.SRP.A.040 (b)

NPA text (c) Within 90 days from receipt of the application …

Comment 90 days should be a maximum delay


Within 90 days maximum from receipt of the application …

Response Accepted

Details of response

Text changed as proposed by commentator

Resulting text (c) Within 90 days maximum from receipt of the application …

CRD RSRP.006/03



of comment


Affected NPA

paragraph

Annex V ADR.SRP Subpart B

NPA text ADR.SPR

Comment No text provided y commentator


ADR.SRP

Response Accepted

Details of response

Apologies for the typing error

Resulting text ADR.SRP (i.e. SuRoundings Protection) across entire Annex V


comment



ADR.SRP.B.010

NPA text

ADR.SPR.B.010 Safeguarding aerodrome surroundings (a) The operator of an international aerodrome shall develop aerodrome safeguarding

maps and provide them to the Authority and to the Municipal Authority responsible for land use in the vicinity of the aerodrome

(b) The operator of a domestic aerodrome open for public use or of a registerd aerodrome shall establish an agreed consultation procedure between them and the relevant Municipal Authorities responsible for land use.

(c) The aerodrome operator of an international aerodrome, of a domestic aerodrome open to public use or of a registered aerodrome, heliport or helideck, shall monitor the aerodrome and it ssurroundings:

(1) Obstacle limitation and protection surfaces as established in the safeguarding maps in (a), and other surfaces and areas associated with the aerodrome, in order to take, within its competence, appropriate action to mitigate the risks associated with the penetration of those surfaces and areas;

(2) Marking and lighting of obstacles in order to be able to take action within its competence , as appropriate; and

(3) Hazards related to human activities and land use in order to take action within its competence, as appropriate.

(d) The aerodrome operator of an international aerodrome shall have procedures in place for mitigating the risks associated with obstacles, developments and other activities within the monitored areas that could impact safe operations of aircraft operating at, to or from the aerodrome.

(e) The procedures in (d) shall include measures to timely limiting, restricting or interrupting air traffic to ensure safety.

(f) In case of measures established following(e), the aerodrome operator of an international aerodrome shall immediately inform air traffic service provider and aeronautical information serviceprovider as appropriate.

Comment Qatar and 'best practices' in general show that these activities are the responsibility of the ANS provider through its AIM department.


(a) The operator of an internationl aerodrome shall make sure that aerodrome safeguarding maps are developed and provided to the Authority and the … Please adapt all requirement text accordingly.

Response Accepted

Details of response

Paragraphs (a) and (b) deleted. (c)(1) modified to comply with the intent of the commentator. Paragraphs renumbered as appropriate.

Resulting text

ADR.SPR.B.010 Safeguarding aerodrome surroundings (a) The operator of an international aerodrome shall develop aerodrome safeguarding

maps and provide them to the Authority and to the Municipal Authority responsible for land use in the vicinity of the aerodrome

CRD RSRP.006/03


(b) The operator of a domestic aerodrome open for public use or of a registerd aerodrome shall establish an agreed consultation procedure between them and the relevant Municipal Authorities responsible for land use.

(c) The aerodrome operator of an international aerodrome, of a domestic aerodrome open to public use or of a registered aerodrome, heliport or helideck, shall monitor the aerodrome and it ssurroundings:

(1) Obstacle limitation and protection surfaces as established in the safeguarding maps in (a) developed on the basis of Article 9, and other surfaces and areas associated with the aerodrome, in order to take, within its competence, appropriate action to mitigate the risks associated with the penetration of those surfaces and areas;

(2) … (3) …

(d) ….


of comment


Affected NPA

paragraph ADR.SRP.B.010 (b)

NPA text

… aerodorme … then … Authroties … inclduing

Comment typos


aerodrome them Authorities including

Response Accepted

Details of response

Apologies for the typos.

Resulting text Paragaph (b) deleted following comment 65 above.



International


ADR.SRP.B.010 (a), (b) and (c)

NPA text

(a) The operator of an internationl aerodrome shall develop aerodrome safeguarding maps and provide them to the Authority and to the Municipal Authority responsible for land use in the vicinity of the aerodrome

(b) The operator of a domestic aerodorme open for public use or of a registerd aerodrome shall establish an agreed consultation procedure between them and the relevant Municipal Authroties responsible for land use.

(c) The aerodrome operator of an international aerodrome, of a domestic aerodrome open to public use or of a registered aerodrome, heliport or helideck, shall monitor the aerodrome and its surroundings:

(1) obstacle limitation and protection surfaces as established in the safeguarding maps in (a), and other surfaces and areas associated with the aerodrome, in order to take, within its competence, appropriate action to mitigate the risks associated with the penetration of those surfaces and areas;

(2) marking and lighting of obstacles in order to be able to take action within its competence, as appropriate; and

(3) hazards related to human activities and land use in order to take action within its competence, as appropriate.

Comment

It is recommended that the safeguarding function remains with Authority as this function is established, communication link with the local authoritie is in place, national stakeholders are aware of the prcess. Overall view is that the safeguarding process is in very mature stage of its development, thus recommended not to be changed.



CRD RSRP.006/03


Response Accepted

Details of response

Article 8 of cover Regulation and Subpart A of Annex V indeed make it clear the prominent role of the Authority for safeguarding aerodromes. Paragraphs (a) and (b) of ADR.SRP.B.010 are hence deleted.

Resulting text

(a) The operator of an internationl aerodrome shall develop aerodrome safeguarding maps and provide them to the Authority and to the Municipal Authority responsible for land use in the vicinity of the aerodrome

(b) The operator of a domestic aerodorme open for public use or of a registerd aerodrome shall establish an agreed consultation procedure between them and the relevant Municipal Authroties responsible for land use.

(c) (a) The aerodrome operator of an international aerodrome, of a domestic aerodrome open to public use or of a registered aerodrome, heliport or helideck, shall monitor the aerodrome and its surroundings:

(1) obstacle limitation and protection surfaces as established in the safeguarding maps in (a), on the basis of Article 8, and other surfaces and areas associated with the aerodrome, in order to take, within its competence, appropriate action to mitigate the risks associated with the penetration of those surfaces and areas;

(2) marking and lighting of obstacles in order to be able to take action within its competence, as appropriate; and

(3) hazards related to human activities and land use in order to take action within its competence, as appropriate.

2.2. Simplified individual responses to additional detailed comments

Originator of the comment


NPA Text Comment Proposed

alternative text

Franz Sammueller Authority/AND franz.sammueller @caa.gov.qa

2.5.5 …, including apron management

Apron Management regarding aircraft movement is done by the ANS department and is not related to the aerodrome operator

RESPONSE Noted (1) The Explanatory Note will not be

republished

id. 2.5.5 (1) … data quality be more specific /


republished

id. 2.5.5 (2) … aerodrome operational services

be more specific /


republished

…, equipment and installations

Be more specific, as e.g. all AGL, Nav-Aids and runway/taxiway signage belong to Authority

/

CRD RSRP.006/03





alternative text


republished

id. 2.5.5 (3) … aerodrome maintenance

Be more specific, as e.g. maintenance of AGL, Nav-Aids and runway/taxiway signage is performed by Authority

/

RESPONSE Noted (5) The Explanatory Note will not be republished

id. 2.5.5 (4)

… responsibilities of the aerodrome operator for apron management


Delete Apron Management related to aircraft movement


id. 2.5.5 (5) … provision of apron management services…

Why does this have to be mentioned if it is not applicable anyway?

rephrase accordingly


id. Article 2 Definitions-6

Apron management Service

Should be according to OTHH procedures

Authority ANS is responsible for all aircraft movement, aerodrome operator is doing the rest

RESPONSE Not accepted (1) Definition in NPA in line with definition in Volume I of ICAO Annex 14

No change

id.

Article 8 Safe-guarding of aerodrome surroundings

Whole paragraph It is not mentioned who is responsible for this activity!


RESPONSE Accepted (1) Article (now numbered 9) rewritten to be clearer on the role of the Authority

See CRD for resulting text

id.

Article 9 Monitoring of aerodrome surroundings

Whole paragraph

It is not defined what is considered by “around”, how far away from the aerodrome? Who is responsible when the AD-operator is no longer responsible?


RESPONSE Accepted (2) Article (now numbered 10) rewritten and referring to the aerodrome safeguard map

See CRD for resulting text

CRD RSRP.006/03





alternative text

id. Annex 1 Definitions for… (10) (b)

… expediting and maintaining…

Safety is missing completely rephrase accordingly

RESPONSE Accepted (3) Modified as proposed by commentator

… safe and orderly flow ….

id. Annex 1 Definitions for… (11)

Aircraft stand Handling, servicing and maintaining is missing completely


RESPONSE Accepted (4) Modified as proposed by commentator

… for parking, handling, servicing and maintaining an aircraft


Category IIIa RVR not less than 175m

According to our LATCI the RVR is not less than 200m


RESPONSE Not accepted (2)

175 m consistent with current edition of ICAO Annex 14. AND may kindly consider amending the LATCI

No change

Category IIIB RVR… see above see above


175 m consistent with current edition of ICAO Annex 14. AND may kindly consider amending the LATCI

No change


LDA Repetition, already mentioned on page 17

delete

RESPONSE Accepted (5) Definition deleted N.A.


LVTO… not less than 75m

Not really applicable, as the majority is QR and QR has different values (CAT C aircraft 125m, CAT D aircraft 150m)



Operator minima shall not be lower that the regulatory ones. No problem if airlines have higher minima; this is often the case.

No change


MLS No MLS available on none of the Qatari Civil Airports

delete

RESPONSE Accepted (6) MLS deleted from definition … using GBAS or ILS where ….

What about other means of landing support, e.g. GBAS?

/ /

CRD RSRP.006/03





alternative text

RESPONSE Accepted (7) GBAS inserted in definition … using GBAS or ILS where ….

TODA Repetition, already mentioned before

delete


TORA Repetition, already mentioned before

delete


taxiway Repetition, already mentioned before

delete


In Annex I to QCAR ADR there are definitions for ‘apron taxiway’ and (more general) for ‘taxiway’, which is more general. Both definitions are also included in EU Regulation 139/2014

No change

id. ADR.OR.C.070 (a) (1)

…, rescue and firefighting, …

ARFFS is not associated to the AD operator

delete

RESPONSE Partially accepted (1) (a)(1) now limited to personnel under direct responsibility of aerodrome operator

See CRD

id.

ADR.OR.D.007 (a) (1) and (2) and (b) (1) and (2)

Aeronautical data activities and aeronautical information provision activities

It is worth mentioning that there is an SLA in place and the work should be done according to the SLA


RESPONSE Accepted (10) New rule ADR.OPS.A.001 introduced to cover explicitly the SLA with AIS provider

id. ADR.OR.D.015 (b) (1)

The aerodrome operator… operational services…

Not clearly described, as it is not the AD operators responsibility if NAV-AIDS, AGL or Airfield signage is concerned (at least not at OTHH)



ADR.OR.D.015 covers the organisation of the aerodrome operator. The fact that some services are provided by other organisations, does not affect this rule.

No change

id. ADR.OR.D.015 (b) (2)

The aerodrome operator… maintenance of each…

Not clearly described, as it is not the AD operators responsibility if NAV-AIDS, AGL or Airfield signage is concerned (at least not at OTHH)


CRD RSRP.006/03





alternative text


ADR.OR.D.015 covers the organisation of the aerodrome operator. The fact that some services are provided by other organisations, does not affect this rule (e.g. the responsible HAI person for maintenance may probably still be charged to maintain the pavements).

No change

id. ADR.OR.D.017 (a)

…operation and maintenance

Not clearly described, as it is not the AD operators responsibility to operate and maintain NAV-AIDS, AGL or Airfield (at least not at OTHH)


RESPONSE Accepted (11)

Reference to rule ADR.OR.C.005(b) introduced: i.e. SLA with service providers to implement training

See CRD

id. ADR.OR.D.017 (c)

… proficiency checks…

Why should the AD operator do that, as they are not responsible? The respective departments at Authority-ANS will do that



The SLA should detail which organisation is responsible for what. Having modified letter (a) of this rule, amending (c) is however not necessary.

Letter (a) modified as stated in response to previous comment

id. ADR.OR.D.017 (d) (1) and (2)

The AD operator shall ensure…

That is just additional workload, as an SLA has to be developed between the relevant stakeholders

/


Instructors and assessors are necessary anyway, whether under responsibility of a service provider based on a SLA, or whether employed by the aerodrome operator. In some areas, the aerodrome operator will be directly responsible (e.g. FOD; removal or rubber from runway, etc.)

No change

id. ADR.OR.D.017 (e) (1), (2) and (3)

The AD operator shall…

How can the AD operator maintain a qualification, if the person performing the work is not under their responsibility

/


If the person is employed by the aerodrome operator the rule applies. If not, a service provider will be responsible, based on the SL

No change

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alternative text

referred in paragraph (a) of this rule.

id. ADR.OR.D.020

Facilities requirements

How can the AD operator ensure that the facility is adequate if they are not responsible for the associated work?

/


Which facilities shall be provided by the aerodrome operator would be defined in the SLA (e.g. electric power for the ILS transmitter or water supply for RFFS)

No change

id.

ADR.OR.D.027 Safety programme and team (a)

Establish and lead… According to the present regulation this is an ANS obligation

/


This is a new regulation, perfectly aligned with par. 2.4.2 of ICAO PANS-ADR (Dc 9981): 2.4.2.1 The State verifies that coordination exists between the aerodrome operator, aeroplane operators, air navigation service providers and all other relevant stakeholders to ensure the safety of operations. 2.4.2.2 The aerodrome operator should ensure that all users of the aerodrome, including ground-handling agencies and other organizations that perform activities independently at the aerodrome in relation to flight or aircraft handling, comply with the safety requirements of the aerodrome operator. The aerodrome operator monitors such compliance.

See CRD for new Article 4 in

Regulation QCAR ADR, which

transposes par. 2.4.2 of ICAO PANS-ADR

id.

ADR.OR.D.027 Safety programme and team (a)

Establish an Aerodrome Safety Team…

This will make the RST obsolete. What about ICAO? (RS-Go Team, etc.) Next to that, this meeting will have a high number of participants, discuss things that are not necessarily of interest for all participants and will eat up a lot of meeting time compared to the now existing RST

/

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alternative text

RESPONSE Partially accepted (2)

At the level of AMC, it will be clarified that the Team may establish Groups, e.g. one dedicated to runway safety = it might be RSG instead of RST, which does not affect the subject of the work. In any case no problem wit ICAO, since RST is mentioned only in Attachment to Volume I of Annex 14 and attachments have only the status of guidance material.

No change

id. Subpart A (ADR.OPS.A. 005) (a)

Determine, document and maintain

Isn’t that the duty of AIS? What about the external surveys?

/


Paragraph (a) in this rule is limited to data under the responsibility of the aerodrome operator (e.g. triggering a NOTAM in case of a hole in the pavement). The wording does not affect the role of the AIS provider

No change

id. ADR.OPS.A.010 (a)

…quality and integrity According to AIS standard, e.g. digital NOTAM standard, etc.



Further details on data quality included in AMC/GM. Not appropriate to mention technical details at the level of legally binding rules

No change

id. ADR.OPS.A.010 (2)

… ensure correct and complete data

Isn’t that included in the external surveys? In addition most of the time, AIS is chasing the AD operator to get the relevant information

not strict enough, should be rephrased


The spirit of the comment is shared. However the legally binding text is considered sufficient to impose specific responsibility on the aerodrome operator for the data which it originates. As last resort, occurrence reports may be used, which may trigger action by the oversight Section of Authority.

No change

id. ADR.OPS.A.015 (a) (1)

… conditions, … Which conditions, this is not specific enough


RESPONSE Noted (8) The comment may be correct, but no more precise text is proposed.

No change

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alternative text

The wording is considered sufficient at the level of legally binding rules. More details in AMC

id. ADR.OPS.A.015 (a) (2)

… navigational aids NAV-AIDS belong to Authority-ANS

delete

RESPONSE Accepted (13) Navigational aids deleted from the paragraph

… facilities and services at the aerodrome.

id. ADR.OPS.A.015 (b)

…changes to air navigation system…

How can the AD operator introduce changes to the air navigation system?


RESPONSE Accepted (14) rephrased

… changes t the infrastructures, facilities or services under its managerial control, the aerodrome operator shall ….

id. ADR.OPS.B.010 (a) (1) (2) (3) (4)

Rescue and firefighting services

ARFFS is part of the Authority-ANS and we are ensuring all of this. Again just additional workload, as an SLA needs to specify the requested

/


New rule ADR.OPS.B.001 introduced, mandating a SLA with RFFS. This rule is now referred in ADR.OPS.B.010

See CRD

id. ADR.OPS.B.010 (b)

… shall establish and implement a training programme

How can the AD operator establish and implement a training program? They are not even responsible for the provision of the service



Reference to a SLA with RFFS included. Depending on the SLA, the aerodrome operator ay have a role for specific learning objectives.

… shall. Directly or through a SLA based on ADR.OPS.B.001 (b), establish …

id. ADR.OPS.B.010 (c)

… shall implement proficiency checks…

How can the AD operator implement proficiency checks? They are not even responsible for the provision of the service


RESPONSE Accepted (17) Text modified

… aerodrome operator shall ensure that the RFFS service provider

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alternative text

implements proficiency ….

id. ADR.OPS.B.010 (e) (1)

…adequately qualified…

This is done by ARFFS rephrase accordingly or delete


Text of rule modified to clarify that records for RFFS personnel will be maintained by RFFS service provider

See CRD


… records… This is done by ARFFS rephrase accordingly or delete

RESPONSE Accepted (19) See response to comment above.

See CRD


… employed by… n/a /

RESPONSE Accepted (20) Paragraph (b)(3) deleted N.A.

id. ADR.OPS.B.010 (f)

Temporary reduction of the level of protection…

Makes no sense rephrase accordingly or delete


Term ‘Authority’ in QCAR ADR means the oversight function of Authority ASD. Not necessary to delete the rule.

No change

id. ADR.OPS.B.015 (a)

… related facilities… report on matters of operational significance

How will the AD operator do that, as the equipment is not under their responsibility?

rephrase accordingly or delete


Pavements, marking, signage, FOD, works on the movement area and other matters are under responsibility of the aerodrome operator.

No change

id. ADR.OPS.B.015 (a) (1)

… air traffic service providers




The expression ‘conditions of the movement area’ is much wider than equipment under responsibility of AND.

No change

id. ADR.OPS.B.015 (b)

…related facilities How will the AD operator do that, as the equipment is not under their responsibility?



Even if some equipment is under responsibility of AND, this does not exempt the aerodrome operator from regularly inspecting the movement area and, should this be the case, inform ATS

No change

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alternative text

id. ADR.OPS.B.030

Surface movement guidance and control system

First question, why? Second question, if this is the aerodrome operator’s obligation, are they paying for it as well?

/


SMGCS includes also e.g. the painted markings on the pavement, which may be under responsibility of the aerodrome operator. Economic arrangements are out of scope of QCAR ADR which focuses on safety.

No change

id. ADR.OPS.B.040

Night Operations How will the AD operator ensure?

/


Either directly or through a SLA. The verb in the rule is ‘ensure’, which indeed covers the case that some services are provided by other organisations.

No change

id. ADR.OPS.B.045

Low visibility operations

How will the AD operator ensure?

/

RESPONSE Not accepted (20) See response to comment above

No change

id. ADR.OPS.B.050

Operations in adverse conditions

How will the AD operator ensure?

/

RESPONSE Not accepted (21) SLA will define respective roles of aerodrome operator and ATS

No change

id. ADR.OPS.B.065

Visual aids How can the AD operator have procedures? The visual aids do not belong to them


RESPONSE Accepted (21) Text rephrased

… procedures to ensure, directly or through arrangements with service providers, that ….

id. ADR.OPS.B.080

…marked and… How should they be marked, where is the standard?


RESPONSE Not accepted (22) The technical details are in Certification Specifications QCS ADR-DSN

No change

id. ADR.OPS.C.015

Visual aids and electrical systems




New rule ADR.OPS.C.001 introduced to mandate a SLA with the involved service provider.

See CRD

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alternative text

id. ADR.OPS.D.005

Apron Management




New rule ADR.OPS.D.001 introduced, to clarify that apron management may be organised through a service provider.

See CRD

id. ADR.OPS.D.010

Management of aircraft…


Not applicable, either rephrase accordingly or delete

RESPONSE Accepted (24) Explicit reference to ADR.OPS.D.001 (i.e. SLA) introduced.

See CRD

id. ADR.OPS.D.015

Coordination of aircraft entry…



RESPONSE Accepted (25) ADR.OPS.D.015 deleted N.A.

id. ADR.OPS.D.020

…services boundary




Even if apron management is provided by ATS, the information on the boundary between the manoeuvring area and the rest of the movement area should be clear.

No change

id. ADR.OPS.D.020

Publication of aeronautical frequencies…

Not applicable as this is an ANS obligation


RESPONSE Accepted (26) Rephrased, to limit the role of the aerodrome operator to only check that this is done.

… shall ensure that … frequencies … are published in AIP….

id. ADR.OPS.D.035

Right of way… Aircraft or vehicles, this is not specific enough



Text identical to ADR.OPS.D.040 in EASA NPA 2013-24

No change

id. ADR.OPS.D.045 (c)

Allocated aircraft stand is communicated to

Not specific enough, who is that? The pilot?


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alternative text

RESPONSE Not accepted (25) Text modelled on ADR.OPS.D.050 in EASA NPA 2013-24

No change

id. ADR.OPS.D.065

Dissemination of information

Not specific enough, who is that? Including airlines? If yes, this is AIS’ duty


RESPONSE Accepted (27) Rephrased to include role of service providers (either AIS or ATS)

… ensure, directly or through the SLA in ADR.OPS.D.00a1 (b), that ….

id. ADR.OPS.D.075

Training for marshallers

Not specific enough. License? rephrase accordingly

RESPONSE Not accepted (26) Competence (i.e. training and qualification) is necessary; not licence.

No change

id. Subpart E Not applicable, why is it mentioned at all?

Done by Authority-ANS rephrase accordingly or delete


Apron Management Service in ICA is standardised in Annex 14 (aerodromes) and hence in scope of QCAR ADR. It is not relevant which organisation is the service provider

No change

id. ADR OPS.E.030

Training of personnel

Not applicable, why the AD operator? Not specific enough, what about licensing? Who is overseeing the training? Who will do the training?



Rephrased to limit role of aerodrome operator, However, at the level of legally binding rules no more details added.

The aerodrome operator or service provider …

id. ADR.SRP.A.030

Application of permit To whom? Not specific enough rephrase accordingly

RESPONSE Not accepted (28) That permissions are issued by Authority is clear in previous rule ADR.SRP.020

No change

id. ADR.SRP.A.040 (b)

…90 days ... the Authority

This is too long To whom?


RESPONSE Partially accepted (5) Word ‘maximum’ included. Nothing prevents Authority to respond earlier.

Within 90 days maximum …

id. ADR.SRP.A.040 (d)

.. the Authority To whom? rephrase accordingly

RESPONSE Not accepted (29) Obviously to the applicant in the rule immediately above.

No change

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alternative text

id. ADR.SRP.A.040 (e)


RESPONSE Not accepted (30) Obviously to the applicant in the rule immediately above.

No change

id. ADR.SRP.A.060


RESPONSE Not accepted (31) Applicant identified in rule ADR.SRP.A.030

No change

id. ADR.SPR.B.010

Safeguarding aerodrome surroundings

Define surroundings; presently the AD operator is not doing that! What is outside of the “surroundings”?


RESPONSE Accepted (28) Reference to safeguard maps in Article 9 of QCAR ADR introduced

(a)(1) … surfaces as established in the safeguarding

2.3. Statistics

Duration of consultation: more than 70 days;

Received comments: 139;

Commentators: 4

o Air Navigation Department (AND) of the QCAA (107 comments);

o Hamad International Airport (HAI)(15 comments);

o Mr Peter Budd (QCAA)(9 comments); and

o Mr Chris Farnaby (8 comments).

The following pie chart depits the portion comments accepted, partially accepted, noted or not accepted:

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In other words, around 60% of the received comments have been accepted or at least partially accepted:

Comments Accepted or at least partially accepted

Noted Not accepted

No. 82 20 37

% 59% 14% 27%

2.4. Overview of the impact of accepted or partially accepted comments

Based on the accepted or partially accepted comments, the general structure and content of the new QCAR ADR has not significantly changed in respect of the text published in the NPA. The role of the service providers (e.g. ATS, AIS, RFFS, ground handling, apron management, maintenance of visual aids, communication, navigation, surveillance or else) active at the aeredrome has been clarified, and it will always be based on mutual agreements to be consolidated in the form of Service Level Agreements (SLA). In particular a new Article 4 has been inserted in the QCAR ADR Regulation, establishing that the aerodrome operator is responsible to ensure that all service providers comply with the operator’s safety management system, which is consistent with paragraph 2.4.2.1 of ICAO PANS-ADR (Doc 9981; first edition 2015) [1]. No changes at all are implemented in the text of the certification specifications QCA ADR-DSN in comparison to the text published in the NPA. An Eplanatory Note on the Q-AMC/GM ADR, which have not undergone public consultation, is contained in following chapter 3.

Comments

Accepted (65) Partially accepted (17) Noted (20) Not accepted (37)

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3. Explanatory Note on first edition of Q-AMC/GM ADR

3.1. Issues to be addressed

Article 15 of the Chicago Convention establishes that every airport in an ICAO contracting State which is open to public use by its national aircraft shall likewise be open under uniform conditions to the aircraft of all the other contracting States. However, Article 68 therein allows a State to designate airports available for international air services. This means that not all aerodromes in Qatar need to be international aerodromes routinely supporting international scheduled commercial air transport and offering appropriate facilitation for this. Furthermore, Article 28 of the same Convention, mandates ICAO contracting States to provide airports and services in accordance with the Standards and Recommended Practices (SARPs) published by ICAO. Therefore the Authority has promulgated Qatar Civil Aviation Regulation on Standards for Aerodrome Design, Operations and Licensing (QCAR ADR) issue 5 in May 2014, based on Annex 14 (aerodromes) to the Chicago Convention. Subsequently, it was felt appropriate, in the context of the RSRP to restructure the rules on aerodromes, in particular to:

split the legally binding 'hard rules' on the processes, performances, privileges and responsibilities (i.e. the QCAR ADR Regulation) from the non-legally binding 'soft rules' (i.e. AMC/GM to implement the Regulation and Certification Specifications for aerdrome design); and

extend the scope beyond the ICAO standards, in order to cover also domestic aerodromes open to public use and registered aerodromes for private use.

Therefore, on 05 March 2017, the first NPA 006/03 on ADR in the context of the RSRP has been published by the Authority, proposing legally binding rules on the legal entities, the regulatory processes, the responsibilities and privileges of the entities. The changes proposed by such NPA aimed at improving harmonisation within the industry, covering the entire range of aerodromes under legal jurisdiction of the State of Qatar, spanning from the international ones with more than one paved runway, to heliports installed on ships registered in Qatar. The changes ensured compliance with ICAO standards and also harmonisation with EASA provisions, where the latter existed. In addition, the proposed Regulation laid down requirements and administrative procedures related to aerodrome certification and oversight. However, for a proper implementation of said Regulation, also Acceptable Means of Complance (AMC) and Guidance Material (GM), covering at least international aerodromes, are necessary. The Authority has hence developed Q-AMC/GM ADR, largely based on corresponding EASA AMC/GM for aerodromes, first edition of 5 March 2014 [6] as modified by its Amendment 1 on 25 May 2016 [7]. The EASA material has however been revised and adapted to the situation in Qatar. The main differences with the corresponding EASA material are in particular:

clearly split between the aerodrome manual and the aerodrome operator manual, to be more suited for the separate certification based on the Regulation QCAR ADR;

more attention to the interface between aerodrome operator and service providers in the frame of the inter-organisational safety management; and

explicit mention of the service providers of Ground Handling, not yet in the scope of EASA.

The first edition of the Q-AMC/GM ADR is focused on international aerodromes. Future NPAs may be published by the Authority to include additional issues in Q-AMC/GM ADR, such as:

Q-AMC/GM for more comprehensive provisions on Ground Handling;

Q-AMC/GM for domestic aerodromes open to public use and related operators;

Q-AMC/GM for private use aerodromes, including heliports; and

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additional possible amendments, depending on the acquired experience and further developments in ICAO or EASA.

The restructuring of the Authority Regulatory framework allows in general for the adaptation of applicable EU 'hard' and 'soft' rules to the context of Qatar, in the perspective of performance-based rules and risk-based oversight, while simultaneously complying with ICAO standards.

3.2. Objectives

The overall objectives of the Authority are defined in Article 4 of Emiri Decree 45 of 2014.

These overall objectives have been pursued through the QCAR ADR Regulation, in particular aiming at six specific objectives.

The associated Q-AMC/GM ADR will contribute to a better achievement of five out of such six specific objectives, as summarised in the table below:

No. Specific Objectives QCAR ADR Regulation Specific Objectives Q-AMC/GM ADR

1

establish and maintain a safe, proportionate and sustainable regulatory framework for aerodromes in the territory of Qatar, in its territorial waters and in its Exclusive Economic Zone (EEZ)

faciltate implementation of QCAR ADR at international aerodromes

2

provide the basis to discharge Qatar’s obligations under the Chicago Convention and its Annexes, in relation to international aerodromes subject to certification

clarify process, requirements and forms for certification or interational aerodromes and related aerodrome operators

3

promote efficiency for operators of more than one international aerodrome, allowing them to acquire a single certificate covering their centralised safety and quality processes

clearly identify subjects to be covered by the aerodrome manual and subjects to be covered by the aerodrome operator manual; the latter including safety management, compliance monitoring and possibly security management

4 allow separate oversight of ground handling service providers

provide form for declaration by ground handling sevice providers

5 provide clear rules for safeguards provide guidance for monitoring of surroundings by aerodrome operator

6 create no prejudice to other applicable legislation in particular for facilitation at international aerodromes

Not applicable to Q-AMC/GM ADR

3.3. Structure of the proposed AMC/GM for international aerodromes

Q-AMC/GM ADR contain 140 AMC and 150 GM, facilitating implementation of new QCAR ADR Regulation, mainly at international aerodromes, suggesting ways to comply with the mentioned Regulation. Two GM support the Articles of cover Regulation QCAR ADR. These GM are identical to EASA correspnding GM, as highlighted in the correspondence matrix in Attachment 1. A second correlation table between the Subparts in EASA AMC/GM for aerodromes and the ones in Q-AMC/GM ADR, is presented in Attachment 2. Although not yet complete, the proposed set of AMC is larger than the corresponding EASA AMC (140 versus 126) due to the wider scope of QCAR ADR and to the split certificates between the aerdorme and the aerodrome operator. Similarly Q-AMC/GM ADR have 150 proposed GM, instead of the 146 in EASA. In particular there are:

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no AMC/GM proposed to Annex I of QCAR ADR (definitions);

a complete set of AMC/GM proposed for Subparts A, B and C of Annex II (Part-ADR.AR), sufficient for certificaton and oversight of international aerodromes;

neither yet proposed AMC/GM for oversight of aerodromes open to public use (i.e. Subpart D; declaration) nor for oversight of aerodromes not open to public use (i.e. Subpart E; registration) in Part-ADR.AR;

a complete set of AMC/GM proposed for Subparts A, B, C, D and H of Annex III (Part-ADR.OR), sufficient for the organisationof an operator managing one or more international aerodromes;

no AMC/GM for Subpart E of Part-ADR.OR which is anyway reserved in QCAR ADR;

only two GM in Subpart F (i.e. declarations) of Part-ADR.OR, proposing forms for the declaration by providers of ground handling services:

not yet proposed AMC/GM in for organisation of the operator of aerodromes open to public use (i.e. still in Subpart F mentioned above) or for operators of aerodromes not open to public use (i.e. Subpart G) in Part-ADR.OR;

a complete set of AMC/GM proposed for Subparts A, B and C of Annex IV (Part-ADR.OPS);

neiter yet proposed AMC/GM for apron management (i.e. Subparts D and E) nor for ground handling (i.e. Subparts F and G) in Part-ADR.OPS;

a limited numbber of AMC/GM to Subpart B (i.e. monitoring of surroundigs) of Annex V (Part-ADR.SRP), but none yet to Subpart A (protections of surroundings).

Further NPAs could hence be developed for the specific topics not yet covered by the first edition of Q-AMC/GM ADR. The reasons for this incomplete publication, are that the missing topics are currently outside of the scope of corresponding EASA AMC/GM, while it was felt urgent to provide AMC/GM applicable to international aerodromes in Qatar. The main features of the first edition of the Q-AMC/GM ADR are highlighted in the following paragraphs.

3.4. Overview of the AMC/GM to the QCAR ADR Regulation

In general the first edition of the Q-AMC/GM ADR transposes the corresponding Acceptable Means of Compliance (AMC) and Guidance Material (GM) for aerodromes, associated with EU Regulation 139/2014 and promulgated by EASA (including Amendment 1) in [6] and [7].

However, the proposed AMC/GM for international aerodromes in Qatar:

are more than the corresponding EASA AMC/GM;

give more emphasis to 'inter-organisational' safety management, which implies strict cooperation between the aerodrome operator and all the service providers active at international aerodromes;

support the split certification (and manuals) between the international aerodrome and its operator;

contain some initial material, albeit limited, addressing service providers of ground handling;

for cost-efficiency purposes, for improved harmonisation and for better inter-organisational safety management, propose to establish a unique 'Aerodrome Safety Team', instead of several Teams;

do not cover winter (e.g. sow, ice) conditions which are no relevant in Qatar.

As explained in 3.3, the proposed "soft rules" are not yet complete. In the interim, before adoption of additional AMC/GM, stakeholders may use material from ICAO documents or from other aviation authorites, or even propose alternative AMC, on the basis of rule ADR.AR.A.015. For this purpose industry standards may be used.

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3.5. Highlights of the proposed Q-AMC/GM for aerodromes

3.5.1. General

The new Regulation QCAR ADR is structured in a cover Regulation plus 5 Annexes. The cover Regulation contains 12 Articles.

Q-AMC/GM ADR contain no AMC to such cover Regulation, but, identical to EASA, one GM to Article 3.2 on functional separation of activities inside the Authority (i.e. separation of the oversight function from operational services provision) and one AMC to Article 9 (protection surfaces).

3.5.2. AMC/GM to Annex I (Part-ADR.DEF) Definitions

Consistent with corresponding EASA 'soft rules' on aerodromes, there are no AMC/GM to Annex I (Part-ADR.DEF).

3.5.3. AMC/GM to Annex II (Part-ADR.AR) Certification and oversight of aerodromes

3.5.3.1 AMC/GM to Supart A (General) of Annex II (Part-ADR.AR)

Subpart A of QCAR ADR is similar to the corresponding Subpart A of EU Regulation [5] and contains general requirements for the work of the Authority, including its scope (ADR.AR.A.001), means of compliance published or accepted by the Authority (ADR.AR.A.015) and reactions to safety problems (ADR.AR.A.030 and 040).

Also the 'soft rules' in Q-AMC/GM ADR are similar to the corresponding EASA ones and comprise two AMC and three GM covering availablity of documentation to third parties, means of compliance (including alternative means of compliance) and reactions to safety problems.

3.5.3.2 AMC/GM to Supart B (Authority's Management) of Annex II (Part-ADR.AR)

Subpart B of QCAR ADR Regulation, still similar to the corresponding EU Regulation, contains requirements for the management of the Authority.

Q-AMC/GM ADR contain 16 AMC (versus 14 in EASA) and 12 GM to this Subpart, whose text is mostly similar to corresponding EASA 'soft rules'.

In fact, two more AMC are added in Q-AMC/GM ADR, to distinguish between international and other aerodromes, which is not the case in EASA, whose current mandate is de facto limited to the former.

In particular AMC1, 2 and 3 to ADR.AR.B.005(1)(b) cover the training programme, the qualification and the recurrent training of aerodrome inspectors and other Authority's personnel involved in certifcation and oversight of aerodromes.

AMC1 to ADR.AR.B.005(1)(d) recommends a compliance monitoring system to be implemented inside the Authority.

Other Q-AMC/GM to this Subpart cover coordination with other authorities, allocation of tasks to qualified entities and record keeping.

3.5.3.3 AMC/GM to Supart C (Oversight, certification and enforcement) of Annex II (Part-ADR.AR)

Subpart C of Regulation QCAR ADR, also similar to [5], has a scope limited to oversight, certification and enforcement in relation to international aerodromes. In particular ‘hard’ rules this Subpart include provisions for defining the certification basis (ADR.AR.C.020) considering also special conditions (ADR.AR.C.025), for handling findings and related corrective actions (ADR.AR.C.055).

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Q-AMC/GM ADR contain 19 AMC and 20 GM to this Subpart.

Two AMC, in comparison to EASA, are added to propose two separate certificate forms, one for the international aerodrome and one for the operator of one or more international aerodromes. Conversely one EASA AMC on separate certification of the aerodrome and the operator is deleted, since in Qatar covered at the leval of Regulation.

GM1 ADR.AR.C.035(e) proposes the form for the terms of approval to be attached to the aerodrome certificate.

Three GM are deleted in comparison to EASA 'soft rules': the single certificate for aerodrome and operator, which is not the case in QCAR ADR; the forms for certificates, since elvated at the level of AMC; and the separate declaration of providers of Apron Management, since this possibility is neither necessary in Qatar, nor present in QCAR ADR.

In particular AMC1 and 2 to ADR.AR.C.010(b) abd (c) support adaptation of the interval beween audits, following the principle of Risk-Based Oversight (RBO), which means less frequent inspections of the aerodrome and of the aerodrome operator, when the Authority can have sufficient confidence in its safety and compliance monitoring system.

Three AMC to ADR.AR.C.015 and two to ADR.AR.C.020 support the initiation of the certification process including the establisment of the certification basis.

Finally, three AMC cover the role of the Authority in relation to change management.

3.5.3.4 AMC/GM to Supart D (Oversight following declaration) of Annex II (Part-ADR.AR)

Subpart D, which covers overisght of domestic aerodromes open to public use and of ground handling service providers, following respective declarations, is reserved in the first edition of Q-AMC/GM ADR.

3.5.3.5 AMC/GM to Supart E (Oversight following registration) of Annex II (Part-ADR.AR)

Subpart E, which covers overisght of aerodromes not open to public use, following respective registration, is equally reserved in the first edition of Q-AMC/GM ADR.

3.5.4. AMC/GM to Annex III (Part-ADR.OR) Organisations at aerodromes

3.5.4.1 AMC/GM to Subpart A (General requirements) of Annex III (Part-ADR.OR)

Subpart A contains general requirements for operators of international aerodromes, including the possibility of using alternative means of compliance (ADR.OR.A.015).

The first edition of Q-AMC/GM ADR contains only one AMC to this Subpart, modeled on the corresponding EASA AMC, which recommends a safety risk assessment if the aerodrome operator proposes a newly developed Alternatve Means of Compliance.

3.5.4.2 AMC/GM to Subpart B (Certification of aerodromes) of Annex III (Part-ADR.OR)

Subpart B of QCAR ADR Regulation, essentially similar to the EU equivalent [5], establishes the process to be followed by an operator of an international aerodrome for the certification of such an airport; this certificate only covers the aerodrome and hence an operator of more than one international airport shall apply and obtain as many certificates as the managed airports. One certificate per aerodrome is the usual practice across the ICAO contracting States, including those belonging to the EU. In this practice, the aerodrome certificate covers also the organisation of the operator and its safety and compliance monitoring management.

On the contrary, in QCAR ADR Regulation, the certification of the aerodrome operator is separately covered by subsequent Subpart C, which allows to achieve economies of scale, since the organisation and management of

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the aerodrome operator, including safety, security and compliance monitoring, could be centralised and described in a single operator's manual and not duplicated in two or several aerodrome manuals.

Because of this split between the certification of the aerodrome and the certificaton of the aerodrome operator, the proposed AMC are less (8 instead of 11) than the corresponding EASA AMC. The same happens for the GM: 8 instead of 10.

In particular three AMC from the corresponding EASA subpart are deleted, since respectively moved to Subpart C (i.e. resources and managers) and to Subpart H (i.e. ADR Manual).

Two GM are equally deleted: resources moved to Subpart C and declaration of providers of apron management not applicable in Qatar.

More in particular:

GM1 ADR.OR.B.010 suggest a familiarisation meeting before intiating the formal certification process;

AMC1 ADR.OR.B.015(b) specifies the information to be provided to the Authority when applying for an aerodrome certificate;

AMC1 ADR.OR.B.015(b)(4) suggests that the applicant should provide written evidence of arrangements with service providers (e.g. Service Level Agreement – SLA), whether contracted or not by the aerodrome operator, and including in particular apron management, ground handling, rescue and firefighting, maintenance of visual aids, aeronautical data and information and air navigation services;

GM1 ADR.OR.B.025(a)(3) proposes a form for the Declaration of Compliance to be submitted by the applicant, which makes reference to the aerodrome certification basis;

One AMC and three GM are dedicated to change management; and

AMC1 ADR.B.065 covers the case of termination of operations.

3.5.4.3 AMC/GM to Subpart C (Certification of aerodrome operators) of Annex III (Part-ADR.OR)

Subpart C lists the requirements for certification of the organisation operating one or more international aerodromes, separate from the aerodrome certificate. The first edition of Q-AMC/GM ADR contains 8 AMC and 5 GM to this Subpart (more than in EASA, where there are respectively four and two), since the separae certification is the only way allowed by QCAR ADR, to allow the operator to achieve economies of scale.

Therefore five AMC are added to cover topics more connected to the organisation of the operator than to the physical infrasctructure. Namely application for operator's certificate; information on the organisation to be included in the applicaion; resources; management personnel and change management.

Three GM are similarly added: resources; form for Decaration of Conformity and changes.

1 AMC (information in AIP), present in EASA 'soft rules' is moved to Subpart ADR.OR.D.

In particular, AMC1 ADR.OR.C.015(b)(5) recommends to the applicant to provide the Authority with informaton on qualification and experiences of the accountable manager and of the other nominated persons at management level.

3.5.4.4 AMC/GM to Subpart D (Management of aerodrome operator) of Annex III (Part-ADR.OR)

Subpart D of QCAR ADR mandates a management system to be implemented by operators of certified international aerodromes. Only such operators are in fact mandated by ICAO Annex 19 [3] to establish a safety management system. To enhance economic efficiency, this Subpart in the QCAR ADR Regulation, allows operators to establish an integrated system (ADR.OR.D.005), e.g. encompassing safety, security and quality (alias compliance monitoring), so optimising the organisational structure.

Key rules in this Subpart of QCAR ADR cover overisght of contractors (ADR.OR.D.010), training of personnel (ADR.OR.D.017), inter-organisational safety management (ADR.OR.D.025) and safety reporting (ADR.OR.D.030).

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The first edition of Q-AMC/GM ADR contains 38 AMC and 34 GM to this Subpart (more than the corresponding 33 AMC and 33 GM in EASA).

The additional AMC mainly cover the safety management system. In fact according to [7] safety processes can be mapped into a 'pyramid' comprising five superimposed layers, as depicted in Figure 1:

Figure 1: Tomasello's pyramid

The aerodrome operator has in fact not only to comply with prescriptive rules (e.g. infrastructure and visual aids), but also to implement mechanisms for reactive (i.e. investigsation on single cases of serious incidents), proactive (i.e. systematic collection of mandatory and voluntary reports on safety occurrences and subsequent statistical analysis) and predictve (ie. safety assessment and mitigation to face or plan changes).

Furthermore, at Qatar international aerodromes, where a number of service providers legally independent from the aerodrome operator do exist, it becomes paramount to cover also 'inter-organisational' safety management.

Therefore four AMC, not having equivalent in EASA, are added to cover reactive, proactive, predictive and inter-organisational safety management. One more additional AMC (information in AIP, being in EASA AMC1 ADR.OR.C.005(c)), is moved into this Subpart ADR.OR.D, from Subpart C above and numbered AMC2 ADR.OR.D.007(b).

More in particular:

AMC1 ADR.OR.D.005(b)(1) recommends a Safety Services Office to support the Safety Manager and a Safety Review Board to which the Saety Manager should report:

AMC1 ADR.OR.D.005(b)(2) recommends a Safety Policy to be signed and promoted by the accountable manager;

two AMC cover the safety risk assessment and mitigation as well as monitoring and measurement of the safety performance;

AMC1 ADR.OR.D.005(b)(6) covers the management of changes;

AMC1 ADR.OR.D.005(b)(8) recommends training on safety management;

AMC1 ADR.OR.D.005(b)(10) recommends the coordination of the emergency response plan;

AMC1 and 2 to ADR.OR.D.005(b)(11) recommends a compliance monitoring (alias quality) system;

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AMC1 ADR.OR.D.005(c) describes the Safety Management Manual, which the operator may wish to incorporate into its Aerodrome Operator Manual, covering the entire organisation and eliminating the need to describe the centralised funtions at aerodrome level;

Two AMC to ADR.OR.D.007 are devoted respectively to the quality and to the security of aeronautical data and aeronautical information, of course for the segment of the data chain under the direct responsibility of the aerodrome operator;

AMC1 ADR.OR.D.010 clarifies the responsibilities of the aerodrome operator in relation to contracted activities;

Five AMC cover the role of the personnel, including the accountable manager, the safety manager and other nominated persons;

GM1 ADR.OR.D.015(b) gives to the aerodrome operator flexibility to reduce the overall number of nominated persons;

Five AMC describe personnel training, including related instructors, assessors and records;

AMC1 ADR.OR.D.027 recommends a single Aerodrome Safety Team, to achieve cost-efficiency, participated by all relevant stakeholders, and having the possibility of establishing specialised groups if necessary (e.g. Runway Safety Group);

AMC1 ADR.OR.D.030 clarifies that the safety reporting has to include voluntary reporting and be particpated by all service providers active on the aerodrome.

3.5.4.5 AMC/GM to Subpart E (reserved) of Annex III (Part-ADR.OR)

This Subpart, which in EASA contains rules on the Aerodrome Manual, is reserved in QCAR ADR Regulation, since the latter envisages an Aerdrome Manual split form the Aerodrome Operator Manual. Both Manuals are covered in Subpart H of Part-ADR.OR.

Consequently the first edition of Q-AMC/GM ADR does not propose any 'soft rule' to this Subpart.

3.5.4.6 AMC/GM to Subpart F (Declarations) of Annex III (Part-ADR.OR)

Subpart F in QCAR ADR contains requirements for organisations signing declarations, such as operators of domestic aerodromes open to public use and ground handling service providers.

These cases have no equivalent in corresponding EASA 'hard' and 'soft rules'.On the contrary, apron managemen service providers are in the scope of EASA rules, but not of QCAR ADR.

Therefore the first edition of Q-AMC/GM ADR containsonly two GM to respectively suggest the form for declaration by Ground Handlers and its attachment.

More 'soft rules' on ground handling may be proposed by subsequent NPAs.

3.5.4.7 AMC/GM to Subpart G (Registration) of Annex III (Part-ADR.OR)

Similarly, Subpart G on registration of aerodromes not open to publuc use, has no equivalent in EASA. Therefore the Subpart is reserved for possible future 'soft rules' on this topic.

3.5.4.8 AMC/GM to Subpart H (Manuals) of Annex III (Part-ADR.OR)

Finally Subpart H of QCAR ADR Regulation, which does not exist in EASA, contains requirements for manuals and documentation, which split between the aerodrome and the aerodrome operator.

The first edition of Q-AMC/GM ADR contains 7 AMC and 6 GM, mainly covering the Aerodrome Manual (one per aerodrome, describing also the infrastructure) and the Aerodrome Operator Manual (a single Manual for an organisation managing one or more aerodromes).

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3.5.5. AMC/GM to Annex IV (Part-ADR.OPS) Aerodrome operations

3.5.5.1 AMC/GM to Subpart A (Aerodrome data) of Annex IV (Part-ADR.OPS)

The first edition of Q-AMC/GM ADR contains 4 AMC and 6 GM to Subpart A on aerodrome data, essentially equivalent to same Subpart in EASA 'soft rules'.

However, one additional GM in comparison to EASA, is introduced to explain the new ICAO types of instrument approaches (i.e. 2D and 3D).

3.5.5.2 AMC/GM to Subpart B (Aerodrome services, equipment and installations) of Annex IV (Part-ADR.OPS)

The first edition of Q-AMC/GM ADR contains 33 AMC and 47 GM to Subpart B essentially equivalent to the corresponding EASA 'soft rules'.

Howeve one AMC is deleted (i.e. winter operations on ice, snow or similar) since not relevant in Qatar, while another AMC, on safeguarding of the surroundings is moved to part-SRP. On these same topics, 3 GM are deleted fro this Subpart, in comparison with EASA,

The total number of AMC remains equal to the EASA 'soft rules' since two additional AMC are proposed, respectivley on external communiations during emergencies and training of RFFS personnel, for which the aerodrome operator has certain responsibilities, even if the sevice is provided by a different organisation.

This Subpart is the one affected by Amendment 1 to corresponding EASA 'soft rules'. Therefore the 2 additional GM introduced by said Amendment 1 tare introduced also in The first edition of Q-AMC/GM ADR:

GM5 ADR.OPS.B.010(a)(2) Rescue and fire fighting services; and

GM6 ADR.OPS.B.010(a)(2) Rescue and fire fighting services

Finally, one more GM is added as GM1 ADR.OPS.B.001 clarifying that:

the aerodrome operator, being responsible for the operation of the aerodrome, should have arrangements and interfaces with service providers or entities to ensure that operational services are provided according to the applicable requirements;

however, the aerodrome operator should not be understood to be directly responsible or liable for non-compliances by another entity or service provider involved in the arrangement.

3.5.5.3 AMC/GM to Subpart C (Aerodrome maintenance) of Annex IV (Part-ADR.OPS)

The first edition of Q-AMC/GM ADR contains 3 AMC and 4 GM to Subpart C, on aerodrome maintenance, essentially equivalent to corresponding EASA 'soft rules', however clarifying that the aerodrome operator may discharge these responsibilities either directly or through Service Level Agreements per ADR.OPS.B.001, ADR.OPS.C.001 and ADR.OPS.F.002.

3.5.5.4 AMC/GM to Subpart D (Responsibility of the aerodrome operator on the apron) of Annex IV (Part-ADR.OPS)

This Subpart D does not exist in corresponding EASA rules.

Furthermore, no providers of apron management services separated from aerodrome operator or seprated from ATS, exist in Qatar.

Consequently the first edition of Q-AMC/GM ADR contains no 'soft rules' to this Subpart.

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3.5.5.5 AMC/GM to Subpart E (Apron management) of Annex IV (Part-ADR.OPS)

For the same reasons explained in 3.5.5.4 immedately above, this NPA proposes no 'soft rules' to Subpart E.

3.5.5.6 AMC/GM to Subpart F (Responsibility of the aerodrome operator for ground handling) of Annex IV (Part-ADR.OPS)

Currently EASA has no regulatory competence on ground handling. Consequently there is no EASA published material on the subject and, thus, the first edition of Q-AMC/GM ADR does not propose any 'soft rule' for Subpart F.

3.5.5.7 AMC/GM to Subpart G (Ground handling) of Annex IV (Part-ADR.OPS)

For similar reasons, Subpart G, intended for provision on ground handling services is reserved in the first edition of Q-AMC/GM ADR.

3.5.6. AMC/GM to Annex V (Part-ADR.SRP) Safeguarding of aerodromes surroundings

Annex V has no EU equivalent, since land use and safeguards in the European Union are responsibility of individual Member States.

In the absence of corresponding EASA 'soft rules', this NPA proposes no 'soft rules' to Subpart A of Part-ADR.SRP, which anyway concerns the Authority, the Air Navigation Services and the applicant/holder of construction permits, but not the aerodrome operator.

Conversely one AMC and two GM are proposed to cover the role of the aerodrome operator to monitor the aerodrome surroundings.

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4. References

4.1. Affected regulations

Qatar Civil Aviation Regulation 006 of 2017 laying down requirements and administrative procedures related to aerodromes.

4.2. Affected CS

None

4.3. Reference documents

[1] ICAO, Procedures for Air Navigation Services – Aerodromes (PANS-ADR), 1st edition, Doc 9981, Montreal, 2015

[2] ICAO, Annex 14 to the Convention on International Civil Aviation, Aerodromes, Volume I, Aerodrome Design and Operations, 7th edition including amendment 13-A, Montreal, July 2016

[3] ICAO, Annex 19 to the Convention on International Civil Aviation, Safety Management, 2nd edition, Montreal, July 2016

[4] ICAO, Manual on Certification of Aerodromes, Doc 9774, 1st edition, Montreal, 2001 [5] Commission Regulation (EU) No 139/2014 of 12 February 2014 laying down requirements and

administrative procedures related to aerodromes pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council

[6] EASA, Acceptable Means of Compliance (AMC) and Guidance Material (GM) to Authority, Organisation and Operations Requirements for Aerodromes, Initial Issue, 05 March 2014

[7] Annex to Decision 2016/009/R, ‘Acceptable Means of Compliance (AMC) and Guidance Material (GM) to Authority, Organisation and Operations Requirements for Aerodromes — Amendment 1’, 25 May 2016

[8] Tomasello's pyramid of safety processes, presented at a Seminar at Parthenope University in naples in 2012

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5. Attachments

5.1. Attachment 1 - Structure of Q-AMC/GM to QCAR ADR cover Regulation in comparison to EASA AMC/GM for aerodromes (including Amendment 1)

STRUCTURE of Q-AMC/GM ADR versus cover Regulation QCAR ADR

Art. Title AMC in EASA Proposed AMC to

QCAR ADR GM in EASA

Proposed GM in QCAR

Notes

1 Subject matter and scope None None None None

2 Definitions None None None None

3 Oversight of aerodromes None None GM1 GM1

4 Aerodrome Operator No equivalent Article in Regulation [5]

None None None

5 Infomation and registration None None None None

6 Exemptions None None None None

7 Conversion of certificates None None None None

8 Devitions from CS None None None None

9 Safeguarding of aerodrome surroundings

None None GM1 GM1

10 Monitoring of aerodrome surroundings

None None None None

11 Wildlife hazard management None None None None

12 Repeal None None None None

13 Entry into force and application None None None None

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5.2. Attachment 2 - Structure of Q-AMC/GM to Annexes of QCAR ADR in comparison to EASA AMC/GM for aerodromes (including Amendment 1)

STRUCTURE of Q-AMC/GM to Annexes and Appendices of QCAR ADR

EASA AMC/GM Subject

AMC/GM to QCAR ADR

Notes

Section No. AMC/GM

Annex I Annex I None Definitions None (Reserved)

Annex II

(Part-ADR.AR)

Title // Authority requirements - Aerodromes

//

Subpart A 2 AMC + 3 GM

General (for Authority) 2 AMC + 3 GM

Subpart B 14 AMC + 12 GM

Management (of Authority)

16 AMC + 12 GM

2 AMC added, to distinguish between international and other aerodromes, which is not the case in EASA

Subpart C 18 AMC + 23 GM

Oversight, certification and enforcement

19 AMC + 20 GM

1 EASA AMC (separate certificates for aerodrome and aerodrome operator) deleted, since already covered by QCAR ADR Regulation.

2 AMC added for respectve certificate forms.

3 GM deleted (single certificate for aerodrome and operator, which is not the case in QCAR ADR; forms for certificates, since elvated at the level of AMC; and separate declaration of providers of Apron Management, not included in QCAR ADR).

Subpart D

Subpart non existing in EASA AMC/GM

Oversight following declarations

RESERVED No material to transpose from EASA

Subpart E


Oversight following registration

RESERVED Out of scope of EASA

Annex III

(Part-ADR.OR)

Title //

Acceptable Means of Compliance and Guidance Material to Part ADR-OR

Organisation Requirements for

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Aerodrome Operators and service providers

Subpart A 1 AMC General 1 AMC

Subpart B 11 AMC + 10 GM

Certification of international aerodromes

8 AMC + 8 GM

Scope of Subpart limited to obligations of operator to certify aerodrome.

3 AMC deleted (resources and managers moved to Subpart C; ADR Manual moved to Subpart H)

2 GM deleted (resources moved to Subpart C and declaration of providers of apron management)


Responsibilities and certification of aerdrome operators of international aerodromes

8 AMC + 5 GM

5 AMC added (application for operator's certificate; info in applicaion; resources; management personnel and changes).

AMC1 ADR.OR.C.005(c) (info in AIP) moved to Subpart ADR.OR.D.

3 GM added (resources; form for Declaration of Conformity and changes)

Subpart D 33 AMC + 33 GM

Management at international aerodromes

38 AMC + 34 GM

5 AMC added (reactive, proactive, predictive and inter-organisational safety management, plus the one moved from Subpart C above)

Subpart E 3 AMC + 3 GM

Aerdrome Manual None (RESERVED)

AMC/GM on Manuals moved to Subpart H

Subpart F


Declarations for domestic aerodromes and service providers

2 GM 2 GM added to provide forms for declaration by Ground Handlers and its attachment

Subpart G .


Registration of aerodromes and heliports not open to public use

RESERVED Out of scope for EASA

Subpart H


Manuals and documents

7 AMC + 6 GM

New Subpart, having no equivalent in EASA, created to split the Aerodrome Manual from the Aerodrome Operator Manual

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Annex IV

Part-ADR.OPS

Title

Acceptable Means of Compliance and Guidance Material to Part ADR-OPS Operations requirements - aerodromes

Subpart A 4 AMC + 5 GM

Aerodrome data 4 AMC + 6 GM

1 GM added to explain the new ICAO types of intrument approaches (i.e. 2D and 3D)

Subpart B

33 AMC + 50 GM

(in EASA AMC/GM after amdt 1)

Aerodrome Operational Services, Equipment and Installations

33 AMC + 47 GM

2 AMC deleted (winter and safeguarding), but 2 added (external communiations and training RFFS personnel).

2 GM following amendment 1 to EASA AMC/GM added:

- GM5 ADR.OPS.B.010(a)(2) Rescue and fire fighting services

- GM6 ADR.OPS.B.010(a)(2) Rescue and fire fighting services

3 GM deleted (winter and 2 for safeguarding).


Maintenance 3 AMC + 4 GM

Subpart D


Aerodrome operator responsibilities on the apron

RESERVED

Subpart E


Provision of apron management services

RESERVED

Subpart F


Aerodrome operator responsibilities for ground handling

RESERVED

Subpart G


Provision of ground handling services

RESERVED

Annex V Title None

Safeguarding of aerodrome

RESERVED

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(Part-ADR.SRP)

surroundings and safeguards

Subpart A


Activities and constructions in aerodrome surroundings

RESERVED

Subpart B


Monitoring of aerodrome surroundings

1 AMC + 2 GM

Documents

Comment Response Document RSRP.006/03 · 5.1. Attachment 1 - Structure of Q-AMC/GM to QCAR ADR cover Regulation in comparison to EASA AMC/GM for aerodromes (including Amendment 1)